15.14.740 − Section B105.1 – Appendix B One and Two Family Dwellings. Section B105.1 of Appendix B is amended to read as follows: The minimum fire-flow requirements for one and two family dwellings having a fire-flow calculation area, which does not exceed 3,600 square feet, shall be 1,500 gallons per minute. Fire flow and flow duration for dwellings having a fire flow calculation area in excess of 3,600 square feet shall not be less than that specified in Table B105.1(1).
15.14.745 − Section B105.2 – Appendix B Buildings Other than One and Two Family Dwellings.
Section B105.2 of Appendix B is amended to read as follows: The minimum fire flow and flow duration for buildings other than one- and two-family dwellings shall be as specified in Table B105.2.
Exception: A reduction in required fire flow of up to 50 percent, as approved, is allowed when the building is provided with an approved automatic sprinkler system installed in accordance with other sections of this code. The resulting fire flow shall not be less than 1,500 gallons per minute for the prescribed duration as specified in Table B105.2.
15.14.750 – Appendix Table B105.1(1) – Appendix B Required fire flow for one and two family dwellings, Group R3 and R4 buildings and townhouses. Appendix B Table B105.1(1) is amended to read as follows:
TABLE B105.1(1)
REQUIRED FIRE-FLOW FOR ONE- AND TWO-FAMILY DWELLINGS, GROUP R-3 AND R-4 BUILDINGS AND TOWNHOUSES
FIRE-FLOW
CALCULATION AREA
(square feet)
AUTOMATIC SPRINKLER SYSTEM
(Design Standard)
MINIMUM FIRE-FLOW
(gallons per minute)
FLOW DURATION
(hours)
0-3,600 No automatic sprinkler system 1,500 2
3,601 and greater No automatic sprinkler system Value in Table B105.1(2)
Duration in Table B105.1(2) at
The required fire-flow rate
0-3,600 Section 903.3.1.3 of the California Fire Code
or Section 313.3 of the California Residential Code
1,500 2
3,601 and greater Section 903.3.1.3 of the California Fire Code or Section 313.3 of the California Residential Code
½ value in
Table B105.1(2)a
Duration in Table B105.1(2) at
The required fire-flow rate
For SI: 1 square foot = 0.0929 m2, 1 gallon per minute = 3.785 L/m. a. The reduced fire-flow shall be not less than 1,500 gallons per minute.
15.14.755 – Appendix Table B105.2 – Appendix B Required fire flow for buildings other than one and two family dwellings, Group R3 and R4 buildings and townhouses. Appendix B Table B105.2 is amended to read as follows:
TABLE B105.2
REQUIRED FIRE-FLOW FOR BUILDINGS OTHER THAN ONE- AND
TWO-FAMILY DWELLINGS, GROUP R-3 AND R-4 BUILDINGS AND TOWNHOUSES
AUTOMATIC SPRINKLER SYSTEM
(Design Standard)
MINIMUM FIRE-FLOW
(gallons per minute)
FLOW DURATION
(hours)
No automatic sprinkler system Value in Table B105.1(2) Duration in Table B105.1(2) Section 903.3.1.1 of the California Fire Code 50% of the value in Table B105.1(2)a
Duration in Table B105.1(2) at the reduced flow rate
Section 903.3.1.2 of the California Fire Code 50% of the value in Table B105.1(2)a
Duration in Table B105.1(2) at the reduced flow rate
For SI: 1 gallon per minute = 3.785 L/m.
a. The reduced fire-flow shall be not less than 1,500 gallons per minute.
15.14.760 - Section C103.1 - Hydrant Spacing. Section C103.1 of Appendix C is amended to read as follows: Fire apparatus access roads and public streets providing required access to buildings in accordance with Section 503 of the California Fire Code shall be provided with one or more fire hydrants, as determined by Section C102.1. Where more than one fire hydrant is required, the distance between 241
Ordinance No.
required fire hydrants shall be in accordance with the City of Cloverdale standards or as approved by the Fire Code Official
15.14.765 - Section C103.2 - Average Spacing. Section C103.2 of Appendix C is deleted
15.14.770 - Section C103.3 - Maximum Spacing. Section C103.3 of Appendix C is deleted
15.14.775 − Table C102.1– Appendix C Footnote Additions. Table C102.1 of Appendix C, footnotes “i” and “j” are added to read as follows:
Table C102.1 Footnote i:
For commercial, industrial and multifamily residential buildings, average spacing shall be no greater than 300 feet.
Table C102.1 Footnote j:
Fire hydrants shall be located within 50 feet of the FDC, or as approved by the Fire Code Official.
15.14.780 – Section D103.1 – Appendix D Access Road Width with A Hydrant. Section D103.1 of Appendix D is deleted.
15.14.785 − Section D103.2 - Appendix D Grade. Section D103.2 of Appendix D is amended to read as follows: Fire apparatus access roads shall be in accordance with the City of Cloverdale standards for public streets or as approved by the Fire Code Official.
15.14.790 − Section D103.3 Appendix D Turning Radius. Section D103.3 of Appendix D is amended to read as follows: The turning radius of a fire apparatus access road shall be not less than 25 feet inside and 45 feet outside unless otherwise approved by the Fire Code Official.
15.14.795 − Section D103.4 Appendix D Dead End. Section D103.4 of Appendix D is amended to read as follows: Dead-end fire apparatus access roads in excess of 150 feet (45720 mm) shall be provided with width and turnaround provisions in accordance with the City of Cloverdale Standards for public streets or as approved by the Fire Code Official.
15.14.800 − Table D103.4 Appendix D Deleted. Appendix D Table D103.4 is deleted.
15.14.805 − Section D103.6 Appendix D Signs. Section D103.6 of Appendix D is amended to read as follows: Where required by the Fire Code Official, fire apparatus access roads shall be marked with permanent NO PARKING-FIRE LANE signs that comply with fire department standards and the California Vehicle Code.
15.14.810 – Section D103.6.1 Appendix D Roads 20 to 26 feet in width. Section D103.6.1 of Appendix D is deleted.
15.14.815 – Section D103.6.2 Appendix D Roads more than 26 feet in width. Section D103.6.2 of Appendix D is deleted.
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Ordinance No.
15.14.820 − Section D104.2 Appendix D Buildings Exceeding 62,000 square feet in Area (Exception). Section D104.2 of Appendix D Exception is deleted.
15.14.825 − Section D106.1 Appendix D Projects having more than 100 Dwelling Units (Exception).
Section D106.1 of Appendix D is amended to delete the exception and read as follows: D106.1 Projects having more than 50 dwelling units. Multiple-family residential projects having more than 50 dwelling units shall be provided with two separate and approved fire apparatus access roads.
15.14.830 − Section D106.2 Appendix D Projects having more than 200 dwelling units. Section D106.2 of Appendix D is deleted.
15.14.835 − Section D107.1 Appendix D – One or Two Family Residential Developments. Section D107.1 is amended to read as follows: Developments of one or two family dwellings with more than 50 dwelling units shall be provided with two separate and approved fire apparatus access roads.
15.14.840 − Section D107.1 Appendix D Exceptions Deletion. Exceptions 1 and 2 to Section D107.1 of Appendix D are deleted.
243
Ordinance No.
Chapter 15.16
CALIFORNIA EXISTING BUILDING CODE
Sections:
15.16.10 Adoption and Citation
15.16.020 Section 1.8.4.2 Fees Chapter One Division I and Section 108.2 Schedule of Permit Fees, Section 108.4 Work Commencing Before Permit Issuance Chapter One Division II
15.16.025 Section 103.1 Creation of Agency
15.16.030 Section 202 Code Official Definition
15.16.040 Section 302.7 Maintenance
15.16.10 − Adoption and Citation. The California Existing Building Code, 2025 edition, including tables and its Appendix A Guidelines for the Seismic Retrofit of Existing Buildings, Chapter A1 Seismic Strengthening Provisions for Unreinforced Masonry Bearing Wall Buildings; Chapter A2 Earthquake Hazard Reduction in Existing Reinforced Concrete and Reinforced Masonry Wall Buildings with Flexible Diaphragms; Chapter A3 Prescriptive Provisions for Seismic Strengthening of Cripple Walls and Sill Plate Anchorage of Light, Wood- Frame Residential Buildings; Chapter A4 Earthquake Risk Reduction in WoodFrame Residential Buildings with Soft, Weak or Open Front Walls; and Chapter A5 Referenced Standards, as set forth in Part 10 of Title 24 of the California Code of Regulations is hereby adopted by reference in its entirety by the City, except that for purposes of citation, said code shall be renumbered by adding "15.16" before the sections of the California Existing Building Code.
15.16.020 – Section 1.8.4.2 Fees of Chapter One Division I and Sections 108.2 Schedule of permit fees, Section 108.4 Work Commencing Before Permit Issuance of Chapter One Division II. Sections 1.8.4.2 Fees of Chapter One Division I and Sections 108.2 Schedule of permit fees and Section 108.4 Investigation Fees of Chapter One Division II are deleted in its entirety: Permit fees, plan review fees and investigation fees shall be assessed as provided in Cloverdale Municipal Code chapter 15.02.
15.16.025 – Section 103.1 Creation of Agency - Section 103.1 is amended as follows: “Insert Name of Department” is hereby deleted and replaced with “City of Cloverdale Building Department.”
15.16.030 – Section 202 Definition – Section 202 Code Official definition is amended to read as follows: The officer or other designated authority charged with the administration and enforcement of this code shall be the Building Official.
15.16.040 – Section 302.6 Maintenance – Section 302.6 is added to read as follows: Buildings and structures, and parts thereof, shall be maintained in a safe and sanitary condition. Devices or safeguards which are required by this code shall be maintained in conformance with the code edition under which installed. The owner or the owner’s designated agent shall be responsible for the maintenance of buildings and structures. To determine compliance with this subsection, the Building Official shall have the authority to require a building or structure to be re-inspected. The requirements of this chapter shall not provide the basis for removal or abrogation of fire protection and safety systems and devices in existing structures.
244
Ordinance No.
Chapter 15.17
CALIFORNIA GREEN BUILDING STANDARDS CODE
Sections:
15.17.010 Adoption and Citation
15.17.040 Section 202 – Definition of “plants - invasive plants”
15.17.050 Section 202 – Definition of “recycled water”
15.17.060 Section 202 – Definition of “water feature”
15.17.010 − Adoption and Citation. The California Green Building Standards Code, 2025 edition, including tables and appendices “A4” and “A5”, as set forth in Part 11 of Title 24 of the California Code of Regulations is hereby adopted by reference in its entirety by the City, as amended herein, except that for purposes of citation, said code shall be renumbered by adding "15.17" before the sections of the California Green Building Standards Code.
15.17.040 – Section 202 – Definition of “plants - invasive plants.” The definition of “PLANTS - Invasive plants” set forth in Section 202 is amended to read as follows: PLANTS - Invasive plants. Invasive plants are species of plants not historically found in California and/or that spread outside cultivated areas and can damage environmental or economic resources as determined by the California Invasive Plant Council (www.cal-ipc.org).
15.17.050 – Section 202 – Definition of “recycled water.” The definition of “RECYCLED WATER” set forth in Section 202 is amended to read as follows: RECYCLED WATER. Tertiary treated water, which results from the treatment of wastewater, and which conforms to the definition of disinfected tertiary recycled water in accordance with state law. Recycled water is suitable for nonpotable direct beneficial uses such as landscape irrigation and water features.
15.17.060 – Section 202 – Definition of “water feature”. The following definition of “WATER FEATURE” is hereby added to Section 202 to read as follows: WATER FEATURE. A design element where open water performs an aesthetic or recreational function. Water features include ponds, lakes, waterfalls, fountains, and artificial streams (where water is artificially supplied). Water feature does not include spas and swimming pools.
245
Ordinance No.
Chapter 15.18
CALIFORNIA REFERENCE STANDARDS CODE
Sections:
15.18.10 Adoption and Citation
15.18.10 − Adoption and Citation. The California Reference Standards Code, 2025 edition, including tables, as set forth in Part 12 of Title 24 of the California Code of Regulations is hereby adopted by reference in its entirety by the City, except that for purposes of citation, said code shall be renumbered by adding "15.18" before the sections of the California Reference Standards Code.
Section 5. Compliance with the California Environmental Quality Act: The City Council finds that this Ordinance is not subject to the California Environmental Quality Act (“CEQA”) pursuant to Sections 15060(c)(2) (the activity will not result in a direct or reasonably foreseeable indirect physical change in the environment) and 15060(c)(3) (the activity is not a project as defined in Section 15378) of the CEQA Guidelines because it has no potential for resulting in physical change to the environment, directly or indirectly.
Section 6. Severability: If any section provision, of this Ordinance or the application thereof to any person or circumstances is for any reason held to be invalid or unconstitutional by a decision of any court of competent jurisdiction or preempted by state legislation, such decision or legislation shall not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have passed this Ordinance and each and every section, subsection, sentence, clause or phrase hereof not declared invalid or unconstitutional without regard to any such decision or preemptive legislation.
Section 7. Effective Date and Publication: This ordinance of the City of Cloverdale shall be effective thirty (30) days after the date of passage. Before the expiration of fifteen (15) days after its passage, this ordinance, or a summary thereof as provided in California Government Code Section 36933, shall be published at least once in a newspaper of general circulation, published and circulated in the City of Cloverdale, along with the names of the members of the City Council voting for and against its passage.
INTRODUCED by the City Council of the City of Cloverdale on the 9th day of November, 2025, and passed and adopted on by the following roll call vote:
AYES: (4) Mayor Lands, Vice Mayor Wolter, Councilmembers: Bagby, Palla NOES: (0)
ABSTAIN: (0)
ABSENT: (1) Councilmember Cruz
Approved: Attested:
____________________ _____________________
Todd Lands, Mayor Mike Maloney, City Clerk
246
City Council/Successor Agency
Agenda Item Summary Meeting Date: December 10, 2025
Agenda Section: Staff Contact:
Kevin Thompson, City Manager
Agenda Item Title:
Consider adoption of the November 2025 Water Supply Assessment (WSA) and Water Supply Verification (WSV) for the proposed Esmeralda Mixed-Use Development Project Recommended Council Action(s):
Adopt a Resolution Entitled, “A Resolution of the City Council of the City of Cloverdale Adopting the Water Supply Assessment and Water Supply Verification for the Proposed Esmeralda MixedUse Development Project in accordance with California Water Code §10910(b) and California Government Code §66473.7(a)(3) and §66473.7(b)(1).
Background:
The Esmeralda Land Company, LP (ELC) is proposing a mixed-use “village” development located on the 266-acre Alexander Valley Resort (AVR) Project site in southeastern Cloverdale, adjacent to the Reuser Industrial Park, the Cloverdale Airport, and the Russian River (see Attachment 1 for a site map). The proposed project would include up to 605 dwelling units, up to 200 resort-hotel rooms, retail, office, light industrial and outdoor and landscaped gathering spaces (the “Project”).
Aside from one small light industrial building, the Project site is currently vacant and mostly undeveloped.
Because of the Project’s size and location, state law requires preparation of a WSA and WSV. The combined WSA/WSV (Attachment 2) evaluates whether the City of Cloverdale (City) has sufficient water supplies to meet the Project’s long-term needs, in addition to existing and planned future uses for the next 20 years.
Using conservative (high) water demand assumptions, including assuming that all 605 units would be occupied by permanent residents, as opposed to being second homes, and that all site landscape irrigation would use the City’s potable water, and using historic water use data from Cloverdale’s 2020 Urban Water Management Plan (UWMP), the WSA/WSV concludes that Cloverdale has adequate water supplies to serve both existing and planned future water uses, as well as the Project, through the 2045 planning horizon – even under drought conditions. In the event of drought, the Project would be subject to the same City-wide conservation measures as other City water users.
The WSA/WSV provides an in-depth review of future hydrologic uncertainties, including the effects of decommissioning the Potter Valley Project (PVP) and the increased frequency of droughts caused by climate change, and cites the City’s ongoing review and Water Resiliency Program (WRP) developments in light of these water supply risks. That said, Cloverdale’s senior water rights and entitlements, and planned WRP infrastructure enhancements support long-term water supply reliability for both current residents and future users like the Project. Because 247
City Council/Successor Agency Agenda Item Summary
Cloverdale may provide water to the Project, state law requires that the City Council (Council) review and adopt the findings of the WSA/WSV.
The draft resolution (Attachment 3) adopting the findings in the WSA/WSV does not approve the underlying Project, which is still undergoing California Environmental Quality Act (CEQA) review.
The resolution only adopts the factual findings in the WSA/WSV. The entitlements for the Project, including any supporting CEQA analysis, will be presented to the Council for approval no sooner than March 2026.
Summary:
The WSA/WSV is a state-required analysis that evaluates whether sufficient water supplies are available to serve developments of a certain size over a 20-year planning horizon. It considers expected water use, growth, and potential drought or supply limitations.
The Project’s WSA/WSV follows these state laws and reached the following conclusions:
1. Projected Demand (Section 4): 76 million gallons per year (MGY) at full buildout by 2040 including landscape irrigation uses. For reference, Cloverdale’s entire 2024 demand was 363 MGY. This estimate is based on standard land use factors consistent with Cloverdale’s latest UWMP and recent City water use trends.
2. Project Efficiency (Sections 4.2, 4.6, and 4.9): the Project’s commitment to water-efficiency design and use of non-potable supplies towards irrigation demands is expected to reduce its total demand well below the projected 76 MGY. This is because the Project will be subject to the latest state building codes, which require low-flow appliances, among other water-saving features.
3. Sufficient Supply (Section 6.4): the City’s pre-1914 senior rights to Russian River underflow and its associated municipal well system – including planned and implemented upgrades - provide a stable and reliable supply under most conditions.
4. Dry-Year Management (Sections 6 and 8): during single or multiple dry years (and droughts), any temporary shortfalls would be addressed through the City’s Water Shortage Continency Plan (WSCP) consistent with the conservative planning assumptions used in its 2020 UWMP.
These policies would apply equally to all system users, including the new Project.
5. Resiliency and Adaptation (Sections 7 and 8): the City’s WRP, ongoing Urban Water Use Objective (UWUO) standards compliance, and planned infrastructure projects (e.g., additional wells, storage, and recycled-water systems) will further enhance long-term water supply reliability – even given potential risk factors such as regulatory curtailments, PVP decommissioning, and future hydrologic uncertainties.
In sum, the WSA/WSV finds that Cloverdale’s water supply will be sufficient to meet all demands – including those of the Project – through 2045, even under drought conditions and considering decommissioning of the PVP. The City’s water shortage response plans (e.g., WSCP) would be used to manage any temporary shortfalls caused by severe droughts. This WSA/WSV conservatively assumes a 76 MGY demand at Project build-out by applying UWMP and standard demand factors, not accounting for the Project’s water-efficient facilities or other supplies 248
City Council/Successor Agency Agenda Item Summary
available to serve landscape uses. Accordingly, the 76 MGY estimate likely overstates the Project’s future water demands.
Cloverdale is preparing its 2025 UWMP Update, which must be adopted by July 1, 2026. The water demands for the project that was previously approved on the AVR site was not included in the 2020 Update, but ELC will coordinate with City staff to ensure that the new Project’s water demands are included in the 2025 UWMP Update.
After the Council reviews the full WSA/WSV it may accept the findings as presented, modify the findings, or provide additional direction to staff.
Options:
1. Approve Resolution as drafted.
2. Amend and approve attached Resolution; or
3. Provide additional direction to staff.
Subcommittee Recommendation:
N/A
Budget/Financial Impact
There is no direct fiscal impact with review and adoption of the report. The Project, if approved, would be subject to the City’s one-time water enterprise impact fees and connection fees, and its future users would be subject to the City’s existing utility user fees and shortage response actions.
In addition, the Project is required to build, at its own expense, a new 500,000-gallon water storage facility on one of the highest elevations on the Project site to improve water resiliency and pressure for “Zone 1” of the City’s existing water distribution system.
Attachments:
1. Resolution
2. Proposed Project Location Map
3. WSA/WSV Document
249
CITY OF CLOVERDALE
CITY COUNCIL
RESOLUTION NO. ___-2025
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CLOVERDALE ADOPTING THE
WATER SUPPLY ASSESSMENT AND WATER SUPPLY VERIFICATION FOR THE PROPOSED
ESMERALDA MIXED-USE DEVELOPMENT PROJECT IN ACCORDANCE WITH CALIFORNIA WATER CODE §10910(b) AND CALIFORNIA GOVERNMENT CODE §66473.7(a)(3) AND §66473.7(b)(1).
WHEREAS, on May 26, 2021, the City of Cloverdale (“City”) adopted its 2020 Urban Water Management Plan Update (“UWMP”) and 2020 Water Shortage Contingency Plan (“WSCP”), as required by the California Urban Water Management Planning Act; and WHEREAS, the UWMP provides the latest information regarding Cloverdale’s water supply availability and reliability, existing and projected demands, and water use efficiency; and WHEREAS, the WSCP provides the latest information regarding Cloverdale’s water shortage stages given specified conditions and corresponding response actions; and WHEREAS, Esmeralda Land Company, LP (“ELC”) has proposed a mixed-use development project (the “Proposed Project”) located on the site of the previously approved Alexander Valley Resort (“AVR”), and given the Proposed Project was not included in the UWMP’s water demands projections, a Water Supply Assessment (“WSA”) and Water Supply Verification (“WSV”) has been prepared pursuant to state law; and
WHEREAS, the Project site is almost entirely vacant and undeveloped, located within the City’s incorporated area and its “Sphere of Influence” per the Sonoma Local Agency Formation Commission, and as such is anticipated to be served potable water by Cloverdale; and WHEREAS, given the anticipated Cloverdale water service, the Proposed Project’s combined WSA/WSV analysis relies on and is consistent with state requirements and Cloverdale’s UWMP and WSCP; and
WHEREAS, given the anticipated Cloverdale water service, and per California Water Code §10910(b), and California Government Code §66473.7(a)(3) and §66473.7(b)(1), the City is responsible for reviewing the contents of the WSA/WSV and adopting its findings; and WHEREAS, the combined WSA/WSV analysis finds that the City is projected to be able to meet the Proposed Project’s water demand – in addition to existing and planned future uses – under normal, single dry, and multiple dry year (drought) conditions through its 2045 planning horizon, acknowledging that the City would implement its WSCP to meet any dry year shortfalls. 250
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Cloverdale has reviewed and hereby adopts the Water Supply Assessment/Water Supply Verification for the proposed Esmeralda Mixed-Use Development on file with the City Clerk and the findings contained therein.
IT IS HEREBY CERTIFIED that the foregoing Resolution was duly adopted by the City Council of the City of Cloverdale at a regular meeting held on December 10, 2025, by the following vote:
Ayes: (__)
Noes: (__)
Absent: (__)
Abstaining: (__)
APPROVED: ATTEST:
___________________________ ___________________________ Todd Lands, Mayor Michael Maloney, City Clerk
251
Path: X:\C40214.01\Maps\EsmeraldaFigures.aprx
Legend
Proposed Project
Location Map
Esmeralda Alexander Valley Resort
City of Cloverdale, CA
November 2025
EKI C40214.01
Attachment 1
Abbreviations
Proposed Project= Esmeralda Land Company's Proposed Project Notes
1. All locations are approximate.
Sources
1. Proposed Project boundary provided by Esmeralda Land Company on 15 May 2025.
2. City of Cloverdale service area boundary provided in 2021 by City of Cloverdale for preparation of City of Cloverdale's 2020 Urban Water Management Plan.
3. Basemap is ESRI's ArcGIS Online world aerial map, obtained 13 November 2025.
Project Site
Sonoma County
Napa County
Sonoma County
City of Cloverdale Service Area
Proposed Project Boundary
0 1,250 2,500 5,000
Feet
Sonoma County
Proposed Project Site
252
Proposed Esmeralda Project –
Water Supply Assessment and Verification (WSA/WSV)
Esmeralda Land Company, LP (ELC) has proposed a mixed-use village-scale development in Cloverdale, a transformative project that will turn 266 acres of currently vacant land - formerly approved as the Alexander Valley Resort (AVR) - into a vibrant new walkable community (the “Project”).
Because the Project qualifies as a “subdivision” under state law and proposes more than 500 units, a Water Supply Assessment and Verification (WSA/WSV) has been prepared. The purpose of the WSA/WSV is to determine whether City of Cloverdale (City) can reliably serve the Project’s water demands, in addition to existing and planned future water uses, consistent with current California regulatory requirements and Department of Water Resources’ guidance.
As required by state law, and because the Project will be served by the City’s municipal water system, the Cloverdale City Council must review and adopt the findings of the WSA/WSV, which include:
Finding WSA/WSV Details Citation
Forecasted
Project
Water
Demands
Projects a conservative demand of 76 MGY1 at buildout (estimated to be about 10 years from now). This estimate is based on standard use factors, consistent with the City’s latest UWMP2 and recent water use trends. The Project will likely be more efficient given modern building standards, high-efficiency fixtures, and non-potable water sources serving Project’s landscape irrigation3.
WSA/WSV
Section 4
(pgs. 13-31)
Cloverdale’s
Sufficient
Water Supply
City’s pre-1914 senior right to Russian River underflow and its municipal well system – and planned upgrades – provide a stable and reliable water supply under most conditions. The City’s right authorizes up to 910 MGY1from the shallow subsurface river flows, substantially exceeding the City’s recent water demands (around 363 MGY1) and UWMP-projected water uses.
WSA/WSV
Section 6
(pgs. 32-45)
Cloverdale’s
Water Supply
Reliability
and Risks
This WSA/WSV includes a more extensive review of the City’s water supply reliability than is typically required, incorporating a hydrologic analysis and evaluation of major risk factors such as curtailments, Potter Valley Project decommissioning, and other climate-change uncertainties. While these present real challenges, the City’s Water Resilience Program, compliance with UWUO4 standards, and planned infrastructure investments (including well rehab and recycled water) are expected to strengthen Cloverdale’s long-term supply reliability.
WSA/WSV
Section 7
(pgs. 46-59)
Dry Year and
Drought
Management
During single or multiple dry years, including droughts, any temporary supply shortfalls would be managed through the City’s Water Shortage Contingency Plan (WSCP), consistent with its UWMP2. As a City water customer, the Project would be required to comply with all WSCP actions and City Council-approved measures during drought or water shortage conditions.
WSA/WSV
Section 8
(pgs. 60-66)
1 MGY = million gallons per year.
2 Refers to Cloverdale’s latest 2020 Urban Water Management Plan (UWMP) update, adopted on 26 May 2021. Per state law, provides the foundational data for WSA/WSV analyses.
3 ELC is planning recycled water or graywater collection systems to offset landscape irrigation demands. 4 Refers to Urban Water Use Objective (UWUO) state-mandated water conservation and water use regulations.
Conclusion: Based on conservative (high) demand assumptions, and in-depth review of supply reliability and risks, the WSA/WSV concludes that Cloverdale is expected to have sufficient and reliable water supplies to meet its projected demands – including those associated with the Project – through the 2045 planning horizon under normal and reasonably foreseeable dry-year conditions. 253
EKI ENVIRONMENT & WATER, INC. www.ekiconsult.com
2001 Junipero Serra Blvd, Suite 300 • Daly City, CA 94014 Water Supply Assessment (WSA) and
Water Supply Verification (WSV)
For the Esmeralda Land Company
Proposed Mixed-Use Development Project
(Located on the Alexander Valley Resort Site)
City of Cloverdale
FINAL – November 2025
EKI C40214.01
254
Water Supply Assessment and Water Supply Verification
Esmeralda Land Company
Mixed-Use Development Project
City of Cloverdale
TABLE OF CONTENTS
1 INTRODUCTION................................................................................................................ 4 WSA/WSV Purpose........................................................................................................ 4 Cloverdale’s UWMP Document..................................................................................... 5 Key WSA/WSV Findings................................................................................................. 6 2 GENERAL REQUIREMENTS FOR THE PREPARATION OF A WSA AND WSV........................... 9 Applicability of CWC, CGC, and State Guidelines to Proposed Project .......................... 9 Responsibility for Preparation of WSA and WSV........................................................... 9 Components of WSA and WSV...................................................................................... 9 3 PROPOSED PROJECT DESCRIPTION................................................................................. 10 4 PROPOSED PROJECT WATER DEMAND ........................................................................... 13 Key Regulations........................................................................................................... 13 Water Use Assumptions.............................................................................................. 16 Resort Areas Water Use .............................................................................................. 16
4.3.1 Resort Hotel Use......................................................................................................16
4.3.2 Resort Apartment Use .............................................................................................16
4.3.3 Expanded Hotel Use................................................................................................. 17
4.3.4 Resort Amenities Uses.............................................................................................17
4.3.5 Surface Parking Use................................................................................................. 17
4.3.6 Resort Pool and Water Features..............................................................................18 Commercial Areas Water Use ..................................................................................... 18
4.4.1 Small Food and Beverage Space Use .......................................................................18
4.4.2 Retail Space Use ......................................................................................................18
4.4.3 Institutional Land Use..............................................................................................18
4.4.4 Office Space Use ......................................................................................................18
4.4.5 Light Industrial Land Use .........................................................................................18 Residential Areas Water Use....................................................................................... 19
4.5.1 Senior Living Community Use ..................................................................................19
4.5.2 Single-Family Residential Use ..................................................................................19
4.5.3 Multi-Family Residential Use ...................................................................................19
4.5.4 Compliance with Conservation Legislation ..............................................................19
4.5.5 Residential Amenities Uses......................................................................................19
4.5.6 Surface Parking Use................................................................................................. 20
4.5.7 Residential Pool and Water Features.......................................................................20 Community Landscaping and Pools Water Use ........................................................... 20
4.6.1 AB 1572 Compliance................................................................................................21 Distribution System Losses.......................................................................................... 22 November 2025 Page 1 of 112 EKI C40214.01
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Existing Water Demand on the Proposed Project Site ................................................ 22 Total Projected Water Demand................................................................................... 22
4.9.1 Total Indoor Water Use ...........................................................................................23
4.9.2 Comparison to UWMP Demands.............................................................................23 5 CITY OF CLOVERDALE WATER DEMAND.......................................................................... 27 Historical Water Demand Within the City Service Area............................................... 27 City Water Demand Projections.................................................................................. 28
5.2.1 Agricultural and Industrial Impacts .........................................................................28 Planned Development Projects within the City Service Area ...................................... 29 Review of Proposed Project’s Inclusion in 2020 UWMP Growth Projections.............. 29 Total Projected City of Cloverdale Water Demand (Inclusive of the Proposed Project) .................................................................................................................................... 29 6 CITY OF CLOVERDALE SERVICE AREA WATER SUPPLY...................................................... 32 Identification of Water Supply Rights.......................................................................... 34 Local Surface Water .................................................................................................... 34
6.2.1 Water Rights............................................................................................................34
6.2.2 Water System..........................................................................................................37
6.2.3 Water Quality ..........................................................................................................38 Groundwater Use........................................................................................................ 38 Total Projected Potable Supply in Normal, Single Dry, and Multiple Dry Years........... 39 7 WATER SUPPLY RELIABILITY AND CONSTRAINTS ............................................................ 46 Hydrologic Variability and Drought Risk ...................................................................... 46
7.1.1 Watershed Drought Conditions...............................................................................47
7.1.2 Sub-Surface Flow Nexus...........................................................................................48 PVP Decommissioning................................................................................................. 49
7.2.1 Timeline and Watershed Efforts..............................................................................49
7.2.2 No Alternative Scenario...........................................................................................50
7.2.3 Anticipated Cloverdale Impacts...............................................................................51 Regulatory Framework and Curtailment Considerations ............................................ 52
7.3.1 Seniority Overview...................................................................................................52
7.3.2 Hydrologic Context..................................................................................................53
7.3.3 Curtailment Risks.....................................................................................................53 Considerations for WSA/WSV Supply Projections....................................................... 54 8 COMPARISON OF SUPPLY AND DEMAND........................................................................ 60 Water Shortage Contingency Planning........................................................................ 60 Urban Water Conservation ......................................................................................... 61 Planned Supplemental Supplies.................................................................................. 62 Supply-Demand Comparison....................................................................................... 64 9 CONCLUSIONS................................................................................................................ 67 10 REFERENCES................................................................................................................... 68 November 2025 Page 2 of 112 EKI C40214.01
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FIGURES
Figure 1 Proposed Project Location
Figure 2 City of Cloverdale Service Area
Figure 3 Local Surface Water Features
Figure 4 NWS Accumulated Precipitation Data for Russian River Watershed at Ukiah from January 1970 to Present
Figure 5 USGS Russian River Flow Data near Cloverdale from January 1970 to Present TABLES
Table 1 Proposed Project Buildout Phasing Schedule (Estimated) Table 2 Proposed Project Water Demands Estimates
Table 3 Proposed Project Landscaping Water Demands Estimates Table 4 Historical Water Demand for the City of Cloverdale Service Area Table 5 Projected Water Demand for the City of Cloverdale Service Area Table 6 Historical Water Supply for the City of Cloverdale Service Area Table 7 Overview of On-Site Water Rights
Table 8 Projected Normal Year Water Supply and Demand
Table 9 Projected Single Dry Year Water Supply and Demand Table 10 Projected Multiple Dry Year Water Supply and Demand Table 11 Russian River Full Natural Flow Data for 2021 to Present Table 12 Aggregated Russian River Watershed Water Rights Compared to Cloverdale Table 13 Projected Normal Year Supplemental Water Supply and Demand
APPENDICES
Appendix A Referenced CGC, CWC, and CBPC Provisions
Appendix B Esmeralda Land Company Mixed-Use Development Project Phasing Plan Appendix C Comparison of Proposed Project GPCD to UWMP Baseline GPCD Appendix D City’s Additional Water Supply Projects Identified in Water Resiliency Program Appendix E Review of Cloverdale Water Supply Access Considerations Appendix F Water Shortage Contingency Plan – Stages, Triggers, and Response Actions November 2025 Page 3 of 112 EKI C40214.01
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1 INTRODUCTION
Included herein is a Water Supply Assessment (WSA) and Water Supply Verification (WSV) for a proposed mixed-use development project (Proposed Project), located on the Alexander Valley Resort project (AVR) site in the City of Cloverdale (Cloverdale or City) 1 in Sonoma County,
California (Sonoma). The Proposed Project is being developed by the Esmeralda Land Company, LP (ELC or Project Proponent). This combined WSA/WSV is compliant with California Water Code (CWC) §10910 et seq. requirements, California Government Code (CGC) §66473.7, California Business and Professions Code (CBPC) §11010, and consistent with the California Department of Water Resources’ (DWR) Guidebook for Implementation of Senate Bill 610 and Senate Bill 221 of 2001: To Assist Water Suppliers, Cities, and Counties in Integrating Water and Land Use Planning, dated 8 October 2003 (Guidebook).
The Proposed Project site (Site or Proposed Project Site) comprises approximately 266 acres across twelve parcels located east of Asti Road (FirstCarbon Solutions, 2025a), as shown on Figure 1. Planned development features include a resort hotel, resort apartments, two resort restaurants, a café, a racquet club, two indoor pavilions, and an outdoor amphitheater with an open space area, as well as associated surface parking. Additional features include specialty retail shops, a boutique hotel, a K–6 private school, a stand-alone office building, light industrial facilities, and a 605-unit residential area, including 200 senior living units, 239 attached residential units (townhomes or stacked units), and 166 detached single-family homes. The Site will also include several playgrounds, a dog park, swimming pools, a fitness center, indoor childcare facilities, a community garden, and additional surface parking (FirstCarbon Solutions, 2025a).
The Proposed Project’s potable water demands and non-potable water uses, such as landscape irrigation, are expected to be met by integrating the Proposed Project into Cloverdale’s municipal water supply system – shown in Figure 2 – via direct connection1 . Accordingly, Cloverdale is
anticipated to act as the primary water service provider for the Proposed Project, utilizing its water supply rights and resources.
Appendix A includes the full text of relevant CWC sections and other requirements referenced in this WSA/WSV. EKI prepared the analysis, tables, and figures in this report to specifically address those requirements, following the Guidebook framework, and to evaluate incorporation of the Proposed Project’s water demands into Cloverdale’s municipal water system.
WSA/WSV Purpose
The statutory and policy intent of this WSA/WSV is to determine whether sufficient water supplies will be available to meet Proposed Project demands once within the City’s service area, 1 The Proposed Project Site is located outside the City’s present potable water distribution and service area (Service Area); however, it is within Cloverdale’s incorporated area per the Sonoma Local Agency Formation Commission’s (Sonoma LAFCo) Resolution No. 2579 (2010) and within its “Sphere of Influence” (SOI) per the Sonoma LAFCo’s latest Municipal Service Review (Sonoma LAFCo, 2014). As such, the entirety of the Site is expected to be connected to and served by Cloverdale’s water distribution system via direct connection.
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during normal, single-dry, and multiple-dry hydrologic years for a 20-year planning horizon2.
Specifically, this WSA/WSV includes a description and analysis of the following:
• WSA/WSV requirements articulated in CWC §10910 et seq. and CGC §66473.7, including a description of how they apply to the Proposed Project;
• Current and projected future water demands of the Proposed Project through the year 2045; • Historical, current, and projected future water demands for the City’s service area through the year 2045;
• Historical, current, and projected future water supplies for the City’s service area through the year 2045;
• Availability of water supplies over a historical 20-year record and proof of the availability of a sufficient future water supply;
• Reasonably foreseeable impacts of the Proposed Project on the availability of water resources for agricultural and industrial uses within the City’s service area; • Extent to which the City or the Project Proponent expects to extract additional groundwater as needed to supply the Proposed Project;
• Comparison of the water supplies and demands for the City service area, including the projected water demands associated with the Proposed Project; and, • City’s latest Water Shortage Contingency Plan (WSCP) actions to be undertaken by the City in response to water supply shortages and drought conditions.
Cloverdale’s UWMP Document
Given the anticipated connection with Cloverdale’s municipal water system, this WSA/WSV is legally required to incorporate data and analyses from the City’s latest Urban Water Management Plan (UWMP) document, which was adopted by the Cloverdale City Council on 26 May 20213. Urban water suppliers, like Cloverdale, are required to update their UWMPs every five years to reflect new data, conditions, and legislative requirements. The current (2020) UWMP provides relevant information regarding Cloverdale’s long-term water supply and demand projections, system operations, supply reliability under various hydrologic conditions, drought risk assessment, and water resilience and response planning.
Cloverdale is soon expected to begin preparing its 2025 UWMP Update, which must be submitted to DWR by 1 July 2026. The Proposed Project’s water demands were not included in the City’s 2020 UWMP. As such, the Project Proponent is planning to coordinate with the City, as appropriate, to ensure the Proposed Project’s water demand projections are incorporated into the 2025 UWMP Update. Additionally, this WSA/WSV includes supplemental analysis of the City’s water supply reliability to reflect recent events (i.e., the 2021 temporary water rights curtailments in Russian River Watershed) that were not addressed in the 2020 UWMP. 2 The CWC and CGC specify that a WSA/WSV must look at supplies and demand on a 20-year planning horizon. 3 Per Cloverdale City Council Resolution No. 044-2021 (26 May 2021).
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Key WSA/WSV Findings
The City obtains its entire water supply from subsurface underflows of the Russian River, accessed under its senior pre-1914 appropriative water right. This long-standing right provides strong regulatory protection and supply reliability, even during drought periods. As documented in the 2020 UWMP, access to these subsurface flows is expected to remain dependable under future hydrologic conditions, supported by the seniority of the City’s water right and planned infrastructure improvements (West Yost, 2025).
Supplemental analyses conducted for this WSA/WSV confirm that while future hydrologic or operational shifts – such as Potter Valley Project (PVP) releases given planned decommissioning or water rights curtailments – could influence local conditions, these effects are expected to be manageable through the City’s existing programs and adaptive planning framework. Based on conservative assumptions consistent with Cloverdale’s 2020 UWMP, the City is projected to meet system-wide demands, including those of the Proposed Project, under normal, single-dry, and multiple-dry year conditions. Any temporary imbalances would continue to be addressed through implementation of the City’s WSCP and demand-management measures.
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Path: X:\C40214.01\Maps\EsmeraldaFigures.aprx
Proposed Project Location
Esmeralda Land Company Mixed-Use
Development Project
City of Cloverdale, CA
November 2025
EKI C40214.01
Figure 1
Abbreviations
Proposed Project= Esmeralda Alexander Valley Resort
Notes
1. All locations are approximate.
Sources
1. Proposed Project boundary provided by Esmeralda Land Company on 15 May 2025.
2. Basemap is ESRI's ArcGIS Online world aerial map,
obtained 13 November 2025.
Legend
Sonoma Creek
Proposed Project Boundary
U.S. Highway 101
Asti Road
0 500 1,000 2,000
Feet
Russian River
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Path: X:\C40214.01\Maps\EsmeraldaFigures.aprx
Legend
City of Cloverdale
Service Area
Esmeralda Land Company Mixed-Use
Development Project
City of Cloverdale, CA
November 2025
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Figure 2
Abbreviations
Proposed Project= Esmeralda Alexander Valley Resort
Notes
1. All locations are approximate.
Sources
1. Proposed Project boundary provided by Esmeralda Land Company on 15 May 2025.
2. City of Cloverdale service area boundary provided in 2021 by City of Cloverdale for preparation of City of Cloverdale's 2020 Urban Water Management Plan.
3. Basemap is ESRI's ArcGIS Online world aerial map, obtained 13 November 2025.
Project Site
Sonoma County
Napa County
Sonoma County
City of Cloverdale Service Area
Proposed Project Boundary
0 1,250 2,500 5,000
Feet
Sonoma County
Proposed Project Site
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2 GENERAL REQUIREMENTS FOR THE PREPARATION OF A WSA AND WSV This section describes the types of projects that trigger the legal requirement for a WSA and WSV, identifies the responsible parties for their preparation, and summarizes the key components that must be included in each. Relevant provisions of the California Government Code (CGC), California Water Code (CWC), and California Business & Professions Code (CBPC) are provided in Appendix A for reference.
Applicability of CWC, CGC, and State Guidelines to Proposed Project The Proposed Project is a mixed-use development that consists of 605 residential dwelling units, meeting the definition of a “Project” pursuant to CWC §10912(a)(1) and requiring a WSA - any project greater than 500 units generally triggers the requirement for a WSA. The Proposed Project also meets the definition of a “Subdivision” pursuant to CGC §66473.7(a)(1), thereby requiring a WSV.
CGC §66473.7(i) provides exemptions from WSV requirements for: (1) projects located within a U.S. Census-defined “Urbanized Area”, (2) projects entirely surrounded by properties developed for urban uses, or (3) housing developments exclusively for very low and low-income households.
The Proposed Project Site is not entirely surrounded by urban development and is not exclusively designated for very low or low-income housing. While the Proposed Project Site lies within the incorporated limits of Cloverdale, the Proposed Project Site is not located near the urban core or downtown area and is not surrounded by established urban land uses. Therefore, it may not fall within a Census-designated Urbanized Area statistic. Given this uncertainty, this WSA/WSV conservatively assumed that the Proposed Project does not qualify as being within an Urbanized Area. As such, the Proposed Project would not meet the exemption criteria under CGC §66473.7(i) and would require a WSV.
Responsibility for Preparation of WSA and WSV
Although the Proposed Project Site is located outside the City’s present water service area (see Figure 2), it lies within Cloverdale’s incorporated area and Sphere of Influence (SOI)
1. Therefore,
water for the Proposed Project should be supplied by the City via direct connection once it is successfully integrated into the City’s municipal water system1. As such, and in accordance with CWC §10910(b), CGC §66473.7(a)(3), and §66473.7(b)(1), the City isresponsible for reviewing the contents of this WSA/WSV and adopting its findings.
Components of WSA and WSV
As set forth in CWC §10910(c)(4) and CGC §66473.7(a)(2), the primary purpose of a WSA/WSV is to determine whether a water supplier has sufficient available water supply to meet all existing and projected demands within the water supplier’s service area, including those generated by the Proposed Project, during normal and dry hydrologic years for a 20-year time horizon4. 4 The CWC and CGC specifies that a WSA/WSV must look at supplies and demand over a 20-year horizon.
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3 PROPOSED PROJECT DESCRIPTION
The Proposed Project is a mixed-use development on an approximately 266-acre site located within Cloverdale1 in Sonoma County, California. The Proposed Project Site includes Assessor’s Parcel Numbers (APNs): 117-050-010, 117-050-011, 117-050-012, 117-050-017, 117-050-024, 117-050-026, 117-050-027, 117-050-028, 117-050-029, 116-260-012, 116-310-013, and 116-310-014 (Esmeralda Land Company, 2025). The Proposed Project Site is bordered by the Reuser Industrial Park and vacant land to the north, the Russian River to the east, the Cloverdale Municipal Airport and vineyards to the south, and Asti Road and U.S. Highway 101 to the west (see Figure 1).
The Proposed Project would construct a mixed-use resort, residential and commercial “village”.
More detailed information on the land uses associated with the proposed village is provided below and in Table 1 (FirstCarbon Solutions, 2025a)5.
• The “Resort Areas” will include up to 200 hotel rooms, 10,203 square foot (sq-ft) of restaurants (including casual & fine dining), 2,200 sq-ft of food services (including a pool bar and café), 4,675 sq-ft spa/onsen, 5,250 sq-ft of recreational facilities (including a sports center rental/eco-center, racquet club and fitness/poolside changing area), 22,405 sq-ft of lobby/meeting rooms, 305 surface parking spaces, and 12,500 sq-ft of pools, spas, and water features.
• The “Commercial Areas” will include 7,300 sq-ft of food services (including a coffee shop and pub), 13,500 sq-ft of miscellaneous specialty shops and a small grocery, 8,000 sq-ft of institutional space, and 17,500 sq-ft of office space. The office space will likely be occupied by a mix of co-working space, professional services and health and wellness clinics. There is also 8,000 sq-ft of light industrial space that will be used for craft maker spaces/artist studios. • The “Residential Areas” will include a 200-unit senior housing development, 166 detached single-family residential (SFR) homes, and 239 attached residential units. The residential area will also provide 5,285 sq-ft of amenities (including a fitness center, childcare and a pool/fitness clubhouse), 110 guest parking spaces, and up to 12,500 sq-ft of pools and water features.
• “Other Uses” within the Proposed Project include:
o An approximately 11,500 sq-ft events space at the resort comprised of an indoor pavilion, a wedding barn, an event gazebo, and an outdoor amphitheater. o Irrigated landscaped area of approximately 1,882,000 sq-ft. This area includes a 20,000 sq-ft “Great Lawn” for tented events and outdoor festivities associated with the resort, a 6,000 sq-ft dog park, a 3,000 sq-ft community garden, and a 4,000 sq-ft playground, all of which are part of the residential area.
5 These estimated land use units and square footages are approximate, and the exact values may change in the future. However, these changes are anticipated to be minor and, therefore, will not affect the outcome of this WSA/WSV.
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As shown in Table 1, the full buildout of the Proposed Project is estimated to occur by 2035 (FirstCarbon Solutions, 2025a). This follows a phased development plan for certain Proposed Project features and facilities, as shown in Appendix B.
Except for one very small light industrial building6, the Proposed Project Site is currently vacant and largely undeveloped. There are no ongoing or recent water uses associated with the Proposed Project Site, and thus no existing water demands are included in the demand projections for this WSA/WSV (FirstCarbon Solutions, 2025a). Although the Proposed Project Site historically supported industrial uses that required water, those operations were terminated and dismantled in the early-1990s7, and no water use has occurred since.
As noted, the Proposed Project Site is located outside of Cloverdale’s existing municipal water service area but within City boundaries; therefore, the entirety of the Proposed Project Site is expected to be incorporated into the City’s water distribution system via direct connection. As such, potable water service will be provided by the City (see Figure 2). 6 Considered a de minimis user given use less than two acre-feet per year per CWC §10721(e). The Proposed Project Site has water rights to divert or pump water from Russian River underflows, documented under SWRCB license numbers 4520, 5931, and 8557, and permit number 20552. No water use activity has been reported under these water rights in recent years.
7 Historically, a large portion of the Site was developed as a timber mill and wood processing plant, along with associated wood waste landfills. These uses were active from the 1950s through the early 1990s, after which they were closed and dismantled.
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Phase 1 Phase 2 Phase 3 Phase 4 Phase 5 Phase 6 Phase 7 2025 2030 2035 2040 2045 Resort Areas
Hotel (Resort) 108,305 0 0 0 0 0 0 108,305 0 108,305 108,305 108,305 108,305 Other (Resort Apartments) 0 0 0 36,400 0 0 0 36,400 0 0 36,400 36,400 36,400 Hotel (Boutique) 0 0 0 0 50,000 0 0 50,000 0 0 50,000 50,000 50,000 Restaurant 10,203 0 0 0 0 0 0 10,203 0 10,203 10,203 10,203 10,203 Food Service (Pool Bar and Café) 2,200 0 0 0 0 0 0 2,200 0 2,200 2,200 2,200 2,200 Fitness Center/Health Club (Spa/Onsen) 4,675 0 0 0 0 0 0 4,675 0 4,675 4,675 4,675 4,675 Fitness Center/Health Club (Rec Facilities) 5,250 0 0 0 0 0 0 5,250 0 5,250 5,250 5,250 5,250 Other - Public Assembly (Meeting Rooms) 22,405 0 0 0 0 0 0 22,405 0 22,405 22,405 22,405 22,405 Surface Parking 305 (c) 0 0 0 0 0 0 305 (c) 0 305 (c) 305 (c) 305 (c) 305 (c) Pool and Water Features (d) 7,500 0 0 0 0 0 0 7,500 0 7,500 7,500 7,500 7,500 7,300 0 0 0 0 0 0 7,300 0 7,300 7,300 7,300 7,300
13,500 0 0 0 0 0 0 13,500 0 13,500 13,500 13,500 13,500 0 0 8,000 0 0 0 0 8,000 0 0 8,000 8,000 8,000
17,500 0 0 0 0 0 0 17,500 0 17,500 17,500 17,500 17,500 0 0 0 0 8,000 0 0 8,000 0 0 8,000 8,000 8,000
0 23,500 23,500 23,500 23,500 23,500 97,500 215,000 0 0 117,500 215,000 215,000 74,358 13,200 87,500 87,567 0 0 0 262,625 0 74,358 262,625 262,625 262,625 0 22,400 22,400 22,400 22,400 22,400 92,975 204,975 0 0 112,000 204,975 204,975 0 0 3,500 1,785 0 0 0 5,285 0 0 5,285 5,285 5,285
0 0 55 (c) 55 (c) 0 0 0 110 (c) 0 0 110 (c) 110 (c) 110 (c) 0 0 0 12,500 0 0 0 12,500 0 0 12,500 12,500 12,500
11,500 0 0 0 0 0 0 11,500 0 11,500 11,500 11,500 11,500 43 (e) 0 0 0 0 0 0 43 (e) 0 43 (e) 43 (e) 43 (e) 43 (e) 20,000 0 0 0 0 0 0 20,000 0 20,000 20,000 20,000 20,000 0 6,000 0 0 0 0 0 6,000 0 0 6,000 6,000 6,000
0 0 3,000 0 0 0 0 3,000 0 0 3,000 3,000 3,000
4,000 0 0 0 0 0 0 4,000 0 4,000 4,000 4,000 4,000
Abbreviations:
Notes:
(a) Land use square footages and number of dwelling units per Reference 1. (b)
(c) Units are Surface Parking spaces.
(d)
(e) Units are acres.
References:
1. FirstCarbon Solutions, 2025a. Draft Esmeralda Alexander Valley Resort Project Addendum, provided by FirstCarbon Solutions on 9 May 2025.
2. Esmeralda Land Company, 2025. Response to Request for Information, provided by Esmeralda Land Company, received 15 May 2025. "sq-ft" = square feet
Surface Parking
Pool and Water Features (d)
Buildout schedule and completion date of 2035 per Reference 1.
Square footage for the pools and water features per Reference 2.
Outdoor Pet Area (Dog Park)
Community Garden
Playground
Great Lawn
Multifamily Housing
Fitness Center/Health Club (Clubhouse)
Other Uses
Other - Public Assembly (Events Space)
Landscaped Area
Single Family Home
Residential Areas
Senior Living Community
Commercial Areas
Food Service (Coffee Shop and Pub)
Retail Store (Specialty and Small Grocery)
Other - Services (Institutional)
Office
Other - Entertainment (Art Studios)
Table 1
Proposed Project Buildout Phasing Schedule (Estimated)
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Land Use (a) Phased Buildout (sq-ft) (b) Land Use at Full Buildout (sq-ft)
Cumulative Buildout (sq-ft) (b)
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4 PROPOSED PROJECT WATER DEMAND
This section presents the estimated water demand for the Proposed Project over a 20-year planning horizon and under normal and dry years2, as noted in Section 2.3. For the purposes of this WSA/WSV, average annual water demands for each land use category associated with the Proposed Project were estimated using standard water demand factors published by federal sources, supplemented with industry benchmarks and calibrated against sector-specific consumption data reported in Cloverdale’s UWMP. These demand factors were applied to planned land uses to develop a conservative estimate of total Proposed Project related water demands at full buildout. Table 2 summarizes the resulting demand projections, inclusive of estimated distribution system losses as further described in Section 4.7.
Key Regulations
The Proposed Project and its associated water use will be subject to existing and future state regulations governing water use efficiency and resource conservation8. The potential impacts of currently applicable regulatory requirements and guidance on projected demands are discussed below.
In 2018, then-Governor Jerry Brown signed Assembly Bill (AB) 1668 and SB 606, establishing the legislative foundation for Making Water Conservation a California Way of Life (the “Conservation Legislation”). This landmark policy framework represents the most significant set of long-term water conservation requirements imposed on urban water suppliers to date. It aims to promote efficient water use, increase drought resilience, and ensure sustainable management of the state’s water resources. The State Water Resources Control Board (SWRCB) adopted the final implementing regulations in July 20249
. Under this state legislation:
• Indoor Residential Water Use Standard – Urban retail water supplies must plan to meet a standard of 55 gallons per capita per day (GPCD) until 1 January 2025, when it changes to 47 GPCD, and then reduces to 42 GPCD beginning 1 January 2030 and thereafter. These values are used to calculate allowable indoor residential demand and will apply to future dwelling units within the Proposed Project.
• Outdoor Residential Water Use Standard – Outdoor irrigation efficiency for residential landscapes will be regulated through a “Landscape Efficiency Factor” (LEF) applied to the reference landscape plant and grass consumption-based water budget10. The allowable LEF will be 0.80 from 2025 through 2034, reduced to 0.63 beginning in 2035 through 2039, and 8 Including those imposed on or by Cloverdale – given the Proposed Project incorporation into its municipal water system – Sonoma County, and pertinent state or federal requirements. 9 See SWRCB’s Making Conservation a California Way of Life Fact Sheet at: waterboards.ca.gov/conservation/regs/ docs/2024/fact-sheet-making-conservation-way-life-revised.pdf 10 LEF is a unitless metric that adjusts reference evapotranspiration based on plant water requirements and irrigation system efficiency. LEF values range from 0.55 (highly efficient irrigation systems with low water-use plants) to 1.0 (special landscape areas), where lower values indicate reduced water consumption through improved irrigation performance and drought-tolerant plant selection (per California Code of Regulations, Title 23, §968(a)).
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0.55 beginning in 2040 and beyond. A low LEF reflects a higher required efficiency in landscape irrigation system performance and plant selection. • Commercial, Industrial, and Institutional (CII) Outdoor Standard – For landscapes served by dedicated irrigation meters in non-residential uses, the same LEF based standard will apply.
This means that beginning in 2025, CII landscapes will also be subject to a maximum LEF of
0.80, declining to 0.63 beginning in 2035 through 2039, and 0.45 beginning in 2040 and beyond; and
• Urban water suppliers are responsible for meeting these system-specific water loss standards, based on calculations made across their entire service area. This means the performance requirement applies to Cloverdale’s municipal water service area as a whole and is not enforced on individual water users or specific developments, including the Proposed Project.
To verify compliance with these regulations, urban water suppliers, like Cloverdale, are required to calculate and report their Urban Water Use Objective (UWUO) beginning in January 2024 and every year thereafter, assessing their water uses against the standards listed above. The Project Proponent is planning to coordinate with the City, as appropriate, to provide data regarding its water uses specific to these requirements and to take corrective actions, as necessary, to ensure it is not adversely impacting the City’s compliance with the Conservation Legislation.
In addition to these major requirements, the following are also relevant to Cloverdale’s water demands, and will apply to the Proposed Project going forward:
• Sonoma County adopted the 2019 California Energy Code and the 2019 California Green Building Standards Code setting minimum standards for construction and building design to enhance efficiency and sustainability (Sonoma County, 2025). • New development and retrofitted landscape water efficiency standards are also governed by California’s Model Water Efficient Landscape Ordinance (MWELO). The MWELO was updated in January 2025 and establishes a structure for planning, designing, installing, maintaining and managing water efficient landscapes in new construction and rehabilitated projects by setting a “Maximum Applied Water Allowance” (MAWA) as an upper limit for water use and reduce water use to the lowest practical amount.
• AB 1572 was signed into law in October 2023 and took effect in January 2024. The legislation prohibits the use of potable water for the irrigation of nonfunctional turf11 on CII properties (excluding cemeteries), on properties managed by homeowners’ associations (HOAs), common interest developments12, and community service organizations or similar entities.
However, AB 1572 does not restrict the use of potable water for irrigating other types of landscaping, such as drought-tolerant or functional plantings, nor does it limit the use of non-potable supplies for any type of landscape irrigation. A discussion of this regulatory 11 Nonfunctional turf is defined as any turf that is not functional turf, and includes turf located within street rights-of-way and parking lots. Nonfunctional turf excludes recreational areas, or areas designated by a property owner or a governmental agency to accommodate human foot traffic for recreation, including, but not limited to, sports fields, golf courses, playgrounds, picnic grounds, or pet exercise areas. 12 A common interest development is defined as a community apartment project, a condominium project, a planned development, or a stock cooperative.
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constraint, in the context of the Proposed Project’s planned irrigation uses, is provided in Section 4.6.1.
New developments in California are required to comply with state mandated water use efficiency standards, established under SB 606, AB 1668 and related updates to MWELO and the California Green Building Standard Code. As such, the Proposed Project will incorporate a range of waterefficient design features and operational practices including, but not limited to:
• Installation of high-efficiency indoor fixtures and appliances, including low-flow lavatory faucets, kitchen faucets, toilets, and urinals consistent with California Green Building Standards Code (CALGreen) performance requirements.
• Implementation of outdoor irrigation systems designed for high efficiency, incorporating smart controllers, pressure regulated spray bodies, drip or subsurface irrigation where feasible, and plan selection consistent with the MWELO and AB 1572 for nonfunctional turf reduction.
• Adherence to residential indoor water use performance targets, limiting residential indoor water use to 42 GPCD in alignment with state Conservation Legislation targets effective 2030 and beyond.
• Use of dedicated irrigation meters or submeters, where applicable for monitoring outdoor water use in non-residential areas and ensuring compliance with CII landscape efficiency targets.
• Incorporation of drought-tolerant landscaping to minimize irrigation needs and increase compliance with future LEF reductions.
These measures ensure that water consumption associated with the Proposed Project is evaluated using conservative assumptions, while also recognizing the actual water use is expected to be lower than calculated demand estimates due to mandatory efficiency standards and the City’s ongoing implementation of its water conservative policies.
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Water Use Assumptions
The water demand estimates presented in this WSA/WSV are derived using industry-standard methodologies commonly applied to new residential, resort, and mixed-use developments.
Specifically, projection factors were sourced from the Energy STAR Portfolio Manager Data Explorer for California, which provides water use intensity factors (WUI Factors) in annual gallons per square foot by property subcategory (the “Energy STAR Data”). These benchmarks are based on national survey results, per-capita and per-dwelling-unit consumption studies, and land use performance data developed in coordination with the U.S. Environmental Protection Agency’s (US EPA) WaterSense Program. By comparison, the City’s 2020 UWMP demand projections reflect historical water use patterns across a broad customer base - encompassing residential, commercial, and municipal users, many of which include older buildings and less efficient landscape practices.
The Proposed Project will be developed entirely as new construction, and therefore subject to modern building efficiency standards, high-performance irrigation requirements, and state drought-response regulations as described in Section 4.1. For this reason, applying Energy STAR’s WUI Factors likely results in intentionally conservative demand estimates, meaning that the actual consumption at build-out may be lower than modeled.
The WUI Factors applied to estimate water demands for the resort, retail, and residential components of the Proposed Project are summarized below. For outdoor water uses categorized under “Other Uses” (including landscape irrigation, pools, and water features), state-approved methodologies were used to calculate demand in accordance with the MWELO and MAWA standards, as detailed in the following subsections.
Resort Areas Water Use
4.3.1 Resort Hotel Use
The Proposed Project’s resort component is anticipated to include a 120-room hotel, with a mix of single and double queen rooms, junior suites and full suite accommodations. At full buildout, the resort building footprint is expected to encompass 108,305 sq-ft of conditional space.
To estimate water demand for this use, the WUI Factor [Hotel] of 0.172 gallons per day per square-foot (gpd/sq-ft). Given this information, the water demand associated with the resort uses is estimated to be 6.8 million gallons per year (MGY) at full buildout. This demand represents around 9% of total projected Proposed Project demands, making the resort a significant but not dominant water use category within the development’s overall demand profile.
4.3.2 Resort Apartment Use
The Proposed Project is expected to include 16 resort-affiliated apartments, which will serve administration staff housing and associated back of house functions such as circulating, support areas and operational space. At full buildout, these units are expected to total 36,400 sq-ft. To November 2025 Page 16 of 112 EKI C40214.01
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estimate water demand for these units the WUI Factor [Other] for the resort apartment uses are estimated to be 0.105 gpd/sq-ft, yielding an estimated demand around 1.4 MGY at full buildout.
This represents approximately 1.8% of total projected Proposed Project demands, indicating that this land use type is a minor contributor to the overall system requirements.
4.3.3 Expanded Hotel Use
In addition to the resort guestrooms, the Proposed Project may add an additional 64 rooms at full buildout, for a total of 50,000 sq-ft. Applying the WUI Factor [Hotel] for these additional hotel rooms is estimated to be 0.172 gpd/sq-ft, yielding an estimated demand of 3.15 MGY at full buildout. This expanded hotel use component would account for approximately 4% of total projected Proposed Project demands.
4.3.4 Resort Amenities Uses
Resort amenities are expected to include a fine dining restaurant and bar, pool bar and café, spa/onsen, fitness center and poolside changing area, racquet club, and sports center rental/ecocenter (collectively, the “Rec Facilities”), and lobby/meeting room spaces. Demands for these amenities were projected using the following:
• Water demands associated with the fine dining restaurant and bar were estimated using the WUI Factor [Restaurant] of 0.358 gpd/sq-ft, yielding an estimated demand of 1.33 MGY at buildout for the 10,203 sq-ft land use.
• Water demands associated with the pool bar and café were estimated using the WUI Factor [Food Service] of 0.452 gpd/sq-ft, yielding an estimated demand of 0.36 MGY at buildout for the 2,200 sq-ft land use.
• Water demands associated with the spa/onsen were estimated using the WUI Factor [Fitness Center/Health Club/Gym] of 0.244 gpd/sq-ft, yielding an estimated demand of 0.42 MGY at buildout for the 4,675 sq-ft land use.
• Water demands associated with the Rec Facilities were also estimated using the WUI Factor [Fitness Center/Health Club/Gym] of 0.244 gpd/sq-ft, yielding an estimated demand of 0.47 MGY at buildout for the 5,250 sq-ft land use.
• Water demands associated with the lobby/meeting room spaces were estimated using the WUI Factor [Other – Public Assembly] of 0.107 gpd/sq-ft, yielding an estimated demand of
0.87 MGY at buildout for the 22,405 sq-ft land use.
Taken together, these resort amenities account for a projected demand around 3.5 MGY at full buildout, around 4.5% of total projected Proposed Project demands.
4.3.5 Surface Parking Use
Included within the Resort Areas portion of the Proposed Project are a total of 305 surface parking spaces to be developed by full buildout. For the purposes of this WSA/WSV, no direct water demand has been assigned to these parking areas, as surface parking facilities do not include irrigation, wash stations, or other water-depending features in the Proposed Project.
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4.3.6 Resort Pool and Water Features
See Section 4.6 for details regarding the estimated water demands for the resort pool and water features.
Commercial Areas Water Use
4.4.1 Small Food and Beverage Space Use
The Proposed Project will include small food and beverage services, such as a coffee shop and pub, totaling approximately 7,300 sq-ft. Water demand associated with this food and beverage space is estimated based on a WUI Factor [Food Service] of 0.452 gpd/sq-ft, yielding an estimated demand around 1.2 MGY at full buildout, around 1.5% of total projected Proposed Project demands.
4.4.2 Retail Space Use
The Proposed Project is also expected to include a small grocery store, and seven miscellaneous shops (e.g., gelato shop, specialty shop, dog grooming/pet supplies, gallery, repairs/rentals, hair and nails). Water demands associated with these uses are estimated based on a WUI Factor [Retail Store] of 0.050 gpd/sq-ft, yielding an estimated demand around 0.25 MGY at full buildout, less than 1% of total projected Proposed Project demands.
4.4.3 Institutional Land Use
The Proposed Project may include a K-6 school. Water demands associated with the school were estimated based on a WUI Factor [Other – Services] of 0.087 gpd/sq-ft, yielding an estimated demand around 0.25 MGY at full buildout, also less than 1% of total projected Proposed Project demands.
4.4.4 Office Space Use
The Proposed Project may include office space, including a co-working space. This water demand is estimated based on a WUI Factor [Office] of 0.046 gpd/sq-ft, yielding an estimated demand around 0.29 MGY at full buildout, also less than 1% of total projected Proposed Project demands.
4.4.5 Light Industrial Land Use
The Proposed Project may include space for artist studios, craft and artisanal manufacturing (“Maker Spaces”), and similar functions. This water demand is estimated based on a WUI Factor [Other – Entertainment] of 0.107 gpd/sq-ft, yielding an estimated demand around 0.31 MGY at full buildout, also less than 1% of total projected Proposed Project demands.
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Residential Areas Water Use
4.5.1 Senior Living Community Use
The Proposed Project is anticipating development of 200 units of senior housing, totaling around 215,000 sq-ft at full buildout. Water demand associated with this senior housing is estimated based on the WUI Factor [Senior Living Community] but scaled down to comply with state conservation guidelines capping future residential indoor water uses (see Section 4.5.4 below) to
0.088 gpd/sq-ft. At full buildout, these demands are estimated to be around 6.92 MGY, around 9% of total projected Proposed Project demands.
4.5.2 Single-Family Residential Use
The single-family residential (SFR) community portion of the Proposed Project is expected to include 166 detached homes, totaling around 262,625 sq-ft at full buildout (averaging 1,582 sqft per home). Water demands associated with this SFR demand are based on the WUI Factor [Single Family Home] similarly scaled down for conservation guidelines to 0.093 gpd/sq-ft. At full buildout, these demands are estimated to be around 8.9 MGY, around 12% of total projected Proposed Project demands.
4.5.3 Multi-Family Residential Use
The multi-family residential (MFR) community portion of the Proposed Project is expected to include 239 attached housing units, totaling around 204,975 sq-ft at full buildout. Water demands associated with this MFR demand are based on the WUI Factor [Multifamily Housing] similarly scaled down for conservation guidelines to 0.096 gpd/sq-ft. At full buildout, these demands are estimated to be around 7.2 MGY, around 9% of total projected Proposed Project demands.
4.5.4 Compliance with Conservation Legislation
As noted in Section 4.1, recent state Conservation Legislation caps future residential indoor water use at 42 GPCD for both SFR and MFR units (the latter including senior housing). Accordingly, the Proposed Project is expected to incorporate high-efficiency fixtures – such as low-flow faucets, toilets, and shower-heads – in compliance with California Green Building Standards Code.
The projected residential indoor water demand for the Proposed Project – not including the resort, retail, and residential amenity uses - based on a peak estimated population of 1,525 residents, is approximately 41.3 GPCD (around 72.9 GPCD when including all non-outdoor Proposed Project water demand).
4.5.5 Residential Amenities Uses
The Proposed Project’s residential area is expected to include a fitness center and childcare space. Water demands associated with these amenities were estimated using the WUI Factor [Fitness Center/Health Club/Gym] of 0.244 gpd/sq-ft, yielding an estimated demand of 0.47 MGY November 2025 Page 19 of 112 EKI C40214.01
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at buildout for the 5,285 sq-ft land use, less than 1% of total projected Proposed Project demands.
4.5.6 Surface Parking Use
Included within the Residential areas of the Proposed Project are a total of 110 surface parking spaces to be developed by full buildout. For the purposes of this WSA/WSV, water demands for surface parking spaces were not calculated as these parking spaces are assumed to have no dedicated or associated water demands.
4.5.7 Residential Pool and Water Features
See Section 4.6 for details regarding the estimated water demands for the residential pool and water features.
Community Landscaping and Pools Water Use
The Proposed Project will include several pools, spas, and water features (collectively referred to as “water features”), and general landscaping. The projected water demands for the community landscaping and water features were estimated based on the MAWA guidelines specified under MWELO. MWELO requires that the annual estimated total water use for planned landscape irrigation and water features not exceed these MAWA guidelines. As shown below, the MAWA is calculated based on the regional reference evapotranspiration rate (DWR, 2012), an evaporation adjustment factor, the total landscaped area, and the area of “special landscaped area”13. This WSA/WSV assumes that water use for the Proposed Project landscaping irrigation and water features will be equal to the MAWA, representing an upper water demand limit of annual applied water for established landscaped areas and water features. 13 Special Landscaped Area includes landscaping dedicated solely to edible plants, recreational areas, areas irrigated with recycled water, or water features using recycled water (DWR, 2025).
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The MAWA is calculated using the following equation:
MAWA = ETo × [(ETAF x LA) + (1-ETAF) × SLA]
where:
ETo = The regional reference evapotranspiration rate14
ETAF = Evapotranspiration Adjustment Factor
For parks (SLAs) = 1.0
For non-residential landscape corridors = 0.45
For residential landscaping = 0.55
For water features = 1
LA = Total landscape area (including SLA)
SLA = Special Landscape Area
Based on the above methodology, the water uses for the Proposed Project’s irrigated landscaping, including the Great Lawn and other uses developments, are estimated to be
26.7 MGY at full buildout, around 35% of total projected water demands for the Proposed Project.
The water uses associated with the pool and water feature components of the Proposed Project, for both the resort and residential communities, are estimated to be 0.61 MGY by full buildout, representing less than 1% of total Proposed Project demands.
The calculations and methodology for these demands are detailed in Table 3.
4.6.1 AB 1572 Compliance
As noted in Section 4.1, AB 1572 prohibits the use of potable water supplies for landscape irrigation in common interest developments and HOAs. Accordingly, it is assumed that the Proposed Project may be prohibited from using Cloverdale’s potable water supply to meet nonfunctional turf12 and general landscape irrigation demands within the Proposed Project common areas.
While potable supplies for irrigation of these areasis prohibited, the WSA/WSV includes irrigation demands in its total potable demand calculations to provide a very conservative maximum potential potable water use scenario. This approach ensures that supply reliability is not underestimated, even if actual potable demand is expected to be lower due to legal restrictions and use of non-potable alternatives.
It is important to note that the landscaped areas in question are intended for recreational and community gathering purposes, such as park spaces, walking paths, and social interaction areas.
These uses support the Proposed Project’s livability and resilience goals and will only depend on potable water, where allowed. As detailed in this WSA/WSV, the Proposed Project anticipates using alternative non-potable supplies – such as recycled water, greywater or captured 14 Location-specific ETo data is required for calculating the MAWA. Reference evapotranspiration data were obtained from Appendix A of the MWELO (California Code of Regulations, Title 23, Division 2, Chapter 2.7) based on values for the Cloverdale. The total annual reference evapotranspiration is 49.4 inches as shown in Table 3.
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stormwater, or use of available water rights for non-potable supplies – to meet these nonpotable irrigation needs, in compliance with applicable regulations.
Distribution System Losses
Most municipal water supply and distribution systems experience some degree of water loss during diversion or intake, treatment, and transmission to end users15. These losses can result from infrastructure inefficiencies such as leaks, routine operational activities like system flushing, or other system-specific factors. While water loss from the newly constructed infrastructure associated with the Proposed Project is expected to be minimal initially, it is reasonable to anticipate that some level of loss and inefficiency will occur over time and as part of normal system operations.
The Proposed Project will be required to comply with California’s Urban Water Use Efficiency Standards, Variances, and Performance Measures, as established under the Conservation Legislation. The Project Proponent will coordinate with Cloverdale, as appropriate, to support water loss monitoring and reporting efforts.
This WSA/WSV conservatively assumes that distribution system losses associated with delivering water to the Proposed Project will be consistent with the average percentage of real and apparent water losses per the validated 2020-2021 Fiscal Year water loss audit submitted by Cloverdale to DWR (i.e., 10.4% of Proposed Project demands; DWR, 2023). All water loss is conservatively considered a “non-recoverable” demand, even though it is recognized that depending on where these losses occur the water may increase recharge for later extraction or contribute to underflows diverted downstream. Table 2 shows that the distribution system losses associated with the Proposed Project are estimated to be 7.9 MGY at buildout.
Existing Water Demand on the Proposed Project Site
As described in Section 3, the Proposed Project Site is currently vacant and undeveloped. While the property historically supported industrial operations that included water use, those activities ceased decades ago and no longer contribute to current or ongoing demands. Accordingly, all water demand associated with the Proposed Project Site in this WSA/WSV reflects new development uses described herein, with no continuation of prior water use.
Total Projected Water Demand
Based on the methodologies and assumptions described above, the total annual water demand for the Proposed Project at full buildout and occupancy is conservatively estimated at approximately 76 MGY (equivalent to 233 acre-feet per year [AFY]), as summarized in Table 2. Of this total, approximately 15 MGY (21%) is attributed to the Resort Uses, 2.4 MGY (3%) to the Commercial Uses, 23.9 MGY (31%) to the Residential Uses, 26.8 MGY (35%) to Other Uses, including outdoor and landscape irrigation (the non-potable uses), and the remaining 7.9 MGY (10%) represents the estimated corresponding distribution system losses. 15 See water.ca.gov/Programs/Water-Use-And-Efficiency/Urban-Water-Use-Efficiency/Validated-Water-Loss-Repor ting for more information.
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4.9.1 Total Indoor Water Use
Based on the above factors, calculations, and assumptions, the total indoor water use for the Proposed Project – including the Resort, Commercial, and Residential Uses - is estimated at 40.6 MGY at full buildout, representing approximately 54% of the Proposed Project’s estimated projected water demand. This estimate incorporates a range of commercial, industrial, and institutional (CII) indoor uses that fall outside certain residential indoor water use standards identified in Section 4.1.
Focusing specifically on permanent residential indoor demand - including the senior living community, single- and multi-family units, and associated distribution system losses - total use is projected at 23 MGY at full buildout. This equates to an estimated per capita residential demand of 41.3 GPCD, consistent with the efficiency standards presented in Section 4.1.
4.9.2 Comparison to UWMP Demands
Tables 4-1 and 4-2 of Cloverdale’s 2020 UWMP provide detailed breakdowns of water demand for both potable and non-potable uses in 2020 and future projections. In that UWMP, Cloverdale’s water use was evaluated under the Water Conservation Act of 2009 (SB X7-7 guidelines), yielding an average gross per capita use of 117 GPCD. This figures likely represent a blend of older and potentially less water-efficient buildings and landscape practices.
The Proposed Project can be expected to increase Cloverdale’s total annual water demand by approximately 45 to 76 MGY, depending on final resort operations and on seasonal use of the Proposed Project’s temporary lodging. These figures include 605 permanent housing units (200 senior housing units, 166 SFR units, and 439 MFR units, as detailed in Table 2) and 200 resortbased temporary housing units (hotel rooms and apartments). The estimated peak permanent residential population at full buildout will be 1,525 people, excluding resort units, which accommodate “transient”16 rather than permanent residents.
A high-level calculation of Proposed Project water use estimated in this WSA/WSV suggests a gross daily per capita demand of approximately 136 GPCD, including landscape irrigation demands17, and around 82 GPCD when excluding landscape irrigation and outdoor water demands (which may be met at least partially with non-potable supplies). While roughly aligned with Cloverdale’s 2020 UWMP projections, the estimate likely overstates actual use, as the Proposed Project will incorporate high-efficiency buildings and landscaping that will be expected to reduce per capita demand below the 82-136 GPCD estimates, as discussed in Sections 4.1 and
4.2. This data is further explored in Appendix C.
16 Transient population refers to people who are temporarily present in a location and do not reside there permanently. These individuals or groups are not considered part of the permanent community, and their stay is typically for a limited duration. 17 Landscape irrigation demands may ultimately be served by non-potable sources, as contemplated by the Proposed Project.
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Table 2
Proposed Project Water Demand Estimates
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California 2025 2030 2035 2040 2045
Resort Areas
120 rooms 108,305 sq-ft 0.172 gpd/sq-ft 0 6.8 6.8 6.8 6.8 Other (Resort Apartments) (c) 16 units 36,400 sq-ft 0.105 gpd/sq-ft 0 0 1.4 1.4 1.4 Hotel (Boutique) 64 rooms 50,000 sq-ft 0.172 gpd/sq-ft 0 0 3.1 3.1 3.1 Restaurant 10,203 sq-ft 0.358 gpd/sq-ft 0 1.33 1.3 1.3 1.3 Food Service (Pool Bar and Café) 2,200 sq-ft 0.452 gpd/sq-ft 0 0.36 0.36 0.36 0.36 Fitness Center/Health Club (Spa/Onsen) 4,675 sq-ft 0.244 gpd/sq-ft 0 0.42 0.42 0.42 0.42 Fitness Center/Health Club (Rec Facilities) 5,250 sq-ft 0.244 gpd/sq-ft 0 0.47 0.47 0.47 0.47 Other - Public Assembly (Meeting Rooms) 22,405 sq-ft 0.107 gpd/sq-ft 0 0.87 0.87 0.87 0.87 Surface Parking (d) 305 spaces -- -- 0 0 0 0 0
Pool and Water Features (e) 7,500 sq-ft -- -- 0 0.23 0.23 0.23 0.23 Commercial Areas
7,300 sq-ft 0.452 gpd/sq-ft 0 1.2 1.2 1.2 1.2
13,500 sq-ft 0.050 gpd/sq-ft 0 0.25 0.25 0.25 0.25
8,000 sq-ft 0.087 gpd/sq-ft 0 0 0.25 0.25 0.25
17,500 sq-ft 0.046 gpd/sq-ft 0 0.29 0.29 0.29 0.29
8,000 sq-ft 0.107 gpd/sq-ft 0 0 0.31 0.31 0.31
Residential Areas
200 units 215,000 sq-ft 0.088 gpd/sq-ft 0 0 3.8 6.9 6.9 166 homes 262,625 sq-ft 0.093 gpd/sq-ft 0 2.5 8.9 8.9 8.9 239 units 204,975 sq-ft 0.096 gpd/sq-ft 0 0 3.9 7.2 7.2 5,285 sq-ft 0.244 gpd/sq-ft 0 0 0.47 0.47 0.47
Surface Parking (d) 110 spaces -- -- 0 0 0 0 0
Pool and Water Features (e) 12,500 sq-ft -- -- 0 0 0.38 0.38 0.38 Other Uses
11,500 sq-ft 0.107 gpd/sq-ft 0 0.45 0.45 0.45 0.45
43 acres -- -- 0 26 26 26 26
Great Lawn 20,000 sq-ft -- -- 0 0.28 0.28 0.28 0.28
6,000 sq-ft -- -- 0 0 0.08 0.08 0.08
3,000 sq-ft -- -- 0 0 0.04 0.04 0.04
4,000 sq-ft -- -- 0 0 0.06 0.06 0.06
-- -- 10.4% -- 0 4.8 7.1 7.9 7.9
0 46 69 76 76
Senior Living Community
Existing Site Demand (i)
Distribution System Losses (h)
Single Family Home (f)
Multifamily Housing (g)
Fitness Center/Health Club (Clubhouse)
Other - Public Assembly (Events Space)
Landscaped Area
Community Garden
Playground
Outdoor Pet Area (Dog Park)
Total (j)
Hotel (Resort) (b)
Other - Services (Institutional)
Land Use Land Use at
Full Buildout
Land Use
Units
Demand
Factor (a)
Demand
Factor Units
Full Buildout Estimated Water Use (MGY)
Specs
Food Service (Coffee Shop and Pub)
Retail Store (Specialty and Small Grocery)
Office
Other - Entertainment (Art Studios)
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Table 2
Proposed Project Water Demand Estimates
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Abbreviations:
"MGY"= million gallons per year "gpcd" = gallons per capita per day "DWR" = California Department of Water Resources "MAWA" = Maximum Applied Water Allowance "sq-ft" = square feet
"FY" = fiscal year
Notes:
(a)
(b)
(c) Includes resort lobby, administration and backrooms, circulation, etc. (d) Water demands for surface parking spaces are excluded from total estimates, as these areas have no associated water demand per Reference 2. (e)
(f)
(g)
(h)
(i)
(j) Totals may not sum due to rounding.
References:
1. 2. FirstCarbon Solutions, 2025a. Draft Esmeralda Alexander Valley Resort Project Addendum, provided by FirstCarbon Solutions on 9 May 2025.
3. California Code of Regulations, Title 23, Division 2, Chapter 2.7, Model Water Efficient Landscape Ordinance.
4. DWR, 2023. WUEdata - 2020 Water Audit Report: City of Cloverdale, accessed 13 May 2025, (https://wuedata.water.ca.gov/awwa_plans).
5. "MWELO" = Model Water Efficient Landscaping
Estimated distribution system water loss is calculated using the City of Cloverdale's FY 2020 DWR Water Audit Report percent water loss (i.e., 10.4% of project demands) per Reference 4 and includes both real and apparent losses.
Existing site demands per Reference 5. The Proposed Project site is currently vacant and undeveloped; therefore, no historical water use is assumed, and existing demands are not included in the demand projections.
The multi-family residential water use factor per Reference 7 is used for calculating the water demand associated with the village flats.
Water use demand factors for the resort hotel, recreational facilities, commercial small F&B, residential amenities; the spa/onsen, lobby/meeting room space, resort small F&B, restaurants, events space, and Commercial Areas; and the institutional and office space all per Reference 1.
Per Project Proponent, guestrooms expected to vary from single/double queen, junior suite, and full suite options ranging 410 sq-ft to 800 sq-ft estimated.
FirstCarbon Solutions, 2025b. Information provided during a meeting with FirstCarbon Solutions, Esmeralda Land Company, City of Cloverdale, and Fehr & Peers on 9 April 2025.
Estimates of the Great Lawn, landscaped area, outdoor residential amenities and pools are based on MWELO MAWA calculations per Reference 3. See Table 3 for MWELO MAWA.
Energy STAR PortfolioManager Data Explorer, Water Use Intensity (gal/sq-ft) by Property Type Subcategory for California year 2023 (75th Percentile shown).
The single-family residential water use factor per Reference 1 is used for calculating the water demand associated with the courtyard and estate homes. "Proposed Project" = Esmeralda Land Company Mixed-Use Development Project
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2025 2030 2035 2040 2045
43 49.4 0.81 0.3 0.37 7,755 25.82 0 25.82 25.82 25.82 25.82
0.46 49.4 0.81 0.3 0.37 83 0.28 0 0.28 0.28 0.28 0.28
0.14 49.4 0.81 0.3 0.37 25 0.08 0 0 0.08 0.08 0.08
0.07 49.4 0.81 0.3 0.37 12 0.04 0 0 0.04 0.04 0.04
0.09 49.4 0.81 0.3 0.37 17 0.06 0 0 0.06 0.06 0.06
0.17 49.4 -- -- 1 -- 0.23 0 0.23 0.23 0.23 0.23
0.29 49.4 -- -- 1 -- 0.38 0 0 0.38 0.38 0.38
0 26 27 27 27
Abbreviations:
"ac" = acre "in" = inches
"DWR" = California Department of Water Resources "MAWA" = Maximum Applied Water Allowance "ETAF" = Evapotranspiration Adjustment Factor "MGY" = million gallons per year "ETo" = Annual Reference Evapotranspiration Rate "WUCOLS" = Water Use Classification of Landscape Species "ETWU" = Estimated Total Water Use
Notes:
(a) Landscaped area per References 1 and 2.
(b) Annual reference evapotranspiration (ETo) rate for Zone 8 per Reference 3. (c) Irrigation Efficiency is 0.81 for drip per Reference 4. (d)
(e) Evapotranspiration Adjustment Factor (ETAF) = [D]/[C], per Reference 4. (f)
(g)
References:
1. 2. Esmeralda Land Company, 2025. Response to Request for Information, provided by Esmeralda Land Company, received 15 May 2025.
3. 4.
5. MAWA should meet or exceed the ETWU. MAWA = [A] x [B] x ETAF x 0.62. ETAF is 0.45 for non-residential areas, per Reference 4. The number in column [G] is converted to MGY.
FirstCarbon Solutions, 2025a. Draft Esmeralda Alexander Valley Resort Project Addendum, provided by FirstCarbon Solutions on 9 May 2025.
DWR, 2012. California Irrigation Management Information System Reference Evapotranspiration Zones, accessed on June 7, 2023. https://cimis.water.ca.gov/Content/pdf/CimisRefEvapZones.pdf.
DWR, 2025. California Code of Regulations, Title 23, Division 2, Chapter 2.7, Model Water Efficient Landscape Ordinance. California Department of Water Resources, updated 2 January 2025.
WUCOLS, 2023. California Center for Urban Horticulture, University of California, Davis. http://ucanr.edu/sites/WUCOLS/. Accessed on 8 June 2023.
ETWU = [A] x [B] x [E] x 0.62, where 0.62 is a conversion factor that converts acre inches per acre per year to gallons per square foot per year, per Reference 4. The number in column [D] is converted to MGY. [G]
Maximum Applied
Water Allowance
(MAWA) (MGY)
(g)
MAWA Estimated Demand (MGY)
Irrigated Landscaping & Outdoor Areas
Landscaped Area
Great Lawn
Playground
Outdoor Pet Area
Community Garden (h)
Pool and Water Features
Resort Areas
Residential Areas
Estimated Total Outdoor Water Use (f)
For non-residential areas, 100% of the plants, excluding edibles and areas using recycled water, shall consist of plants with an average WUCLOS plant factor of 0.30, per Reference 5.
Table 3
Proposed Project Landscaping Water Demands Estimates
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Landscaping Land Use
[A]
Area of Land Use at
Full Buildout (ac)
(a)
[B]
Annual Reference
Evapotranspiration
Rate (ETo) (in)
(b)
[C]
Irrigation Efficiency
(c)
[D]
Plant Factor
(d)
[E]
Evapotranspiration
Adjustment Factor
(ETAF)
(e)
[F]
Estimated Total
Water Use (ETWU)
(f)
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5 CITY OF CLOVERDALE WATER DEMAND
The City’s 2020 UWMP provides estimates of projected future water demand for the City’s present service area (Service Area) in five-year increments, between the years 2025 and 2040 (Cloverdale, 2021). This WSA/WSV includes Proposed Project water demands through estimated full buildout in 2035, and beyond to 204518. Since the UWMP water demand projections for Cloverdale do not extend to 2045, corresponding demand values for this WSA/WSV were estimated by assuming an average growth rate in population consistent with 2025 to 2040 UWMP-defined trends, applied an additional 5-years and yielding a population of 14,061 people – representing a reasonable bound assuming consistent growth in and around Cloverdale. A value of 117 GPCD was applied to the 2045 population for an annual projected water use of 600 MG, consistent with the methodology followed in Section 4.1.2 the City’s 2020 UWMP.
Projected water demand within the City is subdivided between customer sectors or use types (SFR, MFR, commercial/institutional, etc.). As discussed below, the City’s 2020 UWMP demand projections account for: (1) demands for the existing service area and accounts, (2) projected growth based on population and employment estimates, and (3) anticipated new development based on information available to Cloverdale at the time of UWMP preparation.
Historical Water Demand Within the City Service Area
Historical water demand within the City from 2005 through 2024 is summarized in Table 4. Based on water use data from 2020, the majority of the water demand within the Service Area is from the SFR sector, which represented 61% of demand. The remainder of demand was split between commercial/institutional (14% of overall demand), MFR (7.9% of overall demand), agricultural irrigation (7.6% of overall demand), losses (6.1% of overall demand), industrial (1.8% of overall demand), and other (1.5% of overall demand) (Cloverdale, 2021). For reference, SFR accounted for around 54%, commercial/institutional 13%, MFR 7.4%, agricultural 7.5%, and losses around 14% of overall demand per Cloverdale’s prior 2015 UWMP Update (Cloverdale, 2016). This suggests a modest change in demand patterns over time with most percentage changes resulting from progress towards decreasing distribution system losses.
As further shown in Table 4, water use from 2005 to 2008 remained consistent within the Service Area, averaging approximately 487 MGY. A decrease in water use occurred from 2008 to 2010, which generally corresponds with the 2007 to 2009 drought and the economic downturn. Then, a significant drop in water demand occurred in 2014 through 2016 and water demand within the Service Area slightly rebounded from 2017 to 2020 following the historic 2014-2016 drought. The water demand decreased once more from 2021 to 2023, corresponding with the most recent drought, and rebounded to 363 MG in 2024 based on water treatment plant production data provided by the City (Cloverdale, 2025b), reflecting slightly higher values than those presented in the 2020 UWMP to account for operational efficiency. 18 CWC specifies that a WSA/WSV must look at supplies and demand on a 20-year horizon (i.e., to 2043), but given the available data and 2020 UWMP Update service area projection rates, this WSA/WSV looks beyond that to 2045.
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Cloverdale’s average annual water demand of the past three, five, and 10 years was approximately 342 MG (2022-2024), 361 MG (2020-2024), and 367 MG (2015-2024), respectively19. These figures reflect a clear downward trend in water use over time.
City Water Demand Projections
Cloverdale’s 2020 UWMP includes long-range projections of water demand within the City’s Service Area through the year 2040. These projections are based on historical growth trends, current land use planning, and known future developments expected to connect to the City's water system. As mentioned in more detail above, since Cloverdale’s 2020 UWMP water demand projections do not extend to 2045, corresponding demand values for this WSA/WSV were estimated to be 600 MG, consistent with the methodology followed in Section 4.1.2 of the City’s 2020 UWMP.
As presented in Table 5, total annual water demand is estimated to reach approximately 600 MGY by 2045 - not including water demands from the Proposed Project or other planned developments located outside of the current service area.
The Proposed Project lies mostly outside the Service Area, but within incorporated Cloverdale and its SOI, and would be served through a direct connection to the City’s municipal water system1
. Accordingly, the entire water demand of the Proposed Project – both within and outside the Service Area - is considered additive to the City’s existing demand projections in the 2020 UWMP, rather than already accounted for within them.
5.2.1 Agricultural and Industrial Impacts
According to Cloverdale’s 2020 UWMP, agricultural irrigation accounted for approximately 7.6% of total water demands20, while industrial uses – such as the Reuser Industrial Park – accounted for about 1.7% in 2020. These demands are modest relative to the City’s overall water use and have been incorporated into the demand projections through 2045, as reflected in this WSA/WSV.
Available data suggests that possible agricultural irrigation uses served by Cloverdale are limited and are likely associated with small, legacy parcels or urban-edge properties within the City’s service area19. These do not appear to constitute large-scale commercial agricultural operations and are not located in proximity to the Proposed Project Site. Based on available records and land use patterns, no portion of the Proposed Project Site is expected to intersect with or affect water delivery to these users. To the extent that such agricultural parcels exist within the City's water system, they would remain subject to the same water service availability and constraints 19 Equivalent to average annual water demand of roughly 1,050 AFY (2022-2024, three year), 1,108 AFY (2020-2024, five year), and 1,126 AFY (2015-2024, ten year), respectively. 20 UWMP appears to include dedicated landscape irrigation water uses within this total, for instance, irrigation water uses at the City’s Vintage Meadows Park. Additionally, there are around 27 acres of vineyards estimated within and in the immediate vicinity of Cloverdale (per DWR Land Use Viewer, 2023 provisional data); however, it is unclear if these are directly served water from Cloverdale’s municipal system.
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as all other customers, and their supply availability would not be diminished by the Proposed Project.
Beyond the City’s Service Area, the nearest identifiable agricultural operations are located across the Russian River and are not connected to Cloverdale’s water system, located roughly 0.25-1.0 miles away from the Proposed Project Site. These operations are believed to rely on their own surface or groundwater rights and are not known to have any direct or indirect dependence on Cloverdale's municipal supply.
Similarly, modest growth in industrial and commercial water use has been accounted for in the City’s UWMP and is not anticipated to be affected by the addition of the Proposed Project.
Planned Development Projects within the City Service Area The UWMP demand projections incorporate current and historical water usage within the City’s service area, which reflect the City’s best efforts to include the development and growth that has occurred and is projected to occur within the City service area to date (Cloverdale, 2021).
Although demand patterns may fluctuate over time, as is typical in most urban settings, there are few major new developments like the Proposed Project in Cloverdale’s service area. That said, the Baumgardner Ranch Development Project (Baumgardner Ranch) was included in the City’s 2020 UWMP growth and water demand projections (Cloverdale, 2021). The Baumgardner Ranch is a “workforce village” aimed at providing low income, median income, and market rate housing via approximately 300 housing units on approximately 20 acres (FCS, 2020). Since the Baumgardner Ranch demands were included in the City’s 2020 UWMP projections, they are incorporated into this WSA/WSV.
Review of Proposed Project’s Inclusion in 2020 UWMP Growth Projections Since the majority of the Proposed Project Site is located outside the City’s current water service area, the Proposed Project was not included in the growth projections used to develop the City’s 2020 UWMP. Therefore, the water demands associated with the Proposed Project are considered incremental additions to Cloverdale’s 2020 UWMP baseline projections.
Total Projected City of Cloverdale Water Demand (Inclusive of the Proposed Project) Table 5 presents the projected water demands for Cloverdale inclusive of the Proposed Project and other known planned developments. As shown, the Proposed Project contributes no additional demand in 2025 (prior to buildout activities) and is projects to add an estimated 76 MGY to the City’s total water demand by 2035 (at full buildout).
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2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 471 503 500 473 439 436 482 535 569 351 344 343 390 397 394 418 359 339 326 363 Abbreviations:
"MGY" = million gallons per year
Notes:
(a)
(b) The 2020 water use by customer sector per Reference 2. "Loss" refers to distribution system losses, such as operational flushing, leaks, etc.
1. Cloverdale, 2025b. Water Treatment Plant Production Data, provided by the City of Cloverdale on 19 June 2025.
2. Cloverdale, 2021. 2020 Urban Water Management Plan for the City of Cloverdale, prepared by Woodard & Curran, dated May 2021.
Water Demand
Table 4
Historical Water Demand for the City of Cloverdale Service Area Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Historical Water Demand (MGY) (a) (b)
Historical water demands from 2005-2024 per Reference 1.
Reference:
0 100
200
300
400
500
600
20052006200720082009201020112012201320142015201620172018201920202021202220232024 Total Water Use (MG)
Historical Water Demand for the City's Service Area
Single
Family,
61%
Multi-Family,
7.9%
Commercial /
Institutional,
14%
Industrial,
1.8%
Agricultural
Irrigation,
7.6%
Other, 1.5%
Loss, 6.1%
2020 Water Demand by Customer
Sector (b)
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2025 2030 2035 2040 2045 (a)
City 2020 UWMP Demands (b) 532 565 570 583 600
Proposed Project Demands (c) 0 46 69 76 76
532 611 639 659 676
Abbreviations:
"City" = City of Cloverdale "UWMP" = Urban Water Management Plan "gpcd" = gallons per capita per day "WSA" = Water Supply Assessment "MGY" = million gallons per year "WSV" = Water Supply Verification Notes:
(a)
(b) Water demand projections for the City were updated in 2021 per Reference 1. (c)
(d)
Reference:
1. Totals may not sum due to rounding.
Cloverdale, 2021. 2020 Urban Water Management Plan for the City of Cloverdale, prepared by Woodard & Curran, dated May 2021.
Total City Demands (Inclusive of Additive
Proposed Project Demands) (d)
The City’s 2020 UWMP did not provide estimates for projected water demands in 2045. For purposes of this WSA/WSV, 2045 demand values were estimated by assuming an average growth rate in population from 2025 to 2040 to estimate a 2045 population value of 14,061. A gpcd of 117 was applied to the 2045 population projection to estimate an annual projected water use of 600 MGY, consistent with the methodology followed in the 2020 UWMP.
The City's 2020 UWMP demands are inclusive of the Baumgardner Ranch Development Project, an approximately 300 housing unit development over 20 acres, which is incorporated into the City's latest growth and water demand projections per Reference 1.
As discussed in Section 5 of the WSA/WSV, the Proposed Project demands are not included within the 2020 UWMP and are, therefore, considered additive to City demands. "Proposed Project" = Esmeralda Land Company Mixed-Use
Development Project
Table 5
Projected Water Demand for the City of Cloverdale Service Area Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Water Demand Projected Annual Water Demand (MGY)
532 565 570 583 600
46 69 76 76
0 100
200
300
400
500
600
700
2025 2030 2035 2040 2045 (a)
Total Projected Water Use (MG)
Projected City Water Use
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6 CITY OF CLOVERDALE SERVICE AREA WATER SUPPLY
This section describes water supplies available to the City that would also serve the Proposed Project upon connection to its municipal water system. It evaluates the reliability and variability of those supplies under normal year, single-dry-year, and multiple-dry year (drought) conditions, as well as other operational and regulatory factors that may influence long-term availability.
According to the City’s 2020 UWMP, Cloverdale’s water supply portfolio consists exclusively of subsurface underflows of the Russian River pumped from wells, classified as “under the direct influence of surface water”21. These supplies are accessed under the City’s senior pre-1914 appropriative water right, which provides a high level of legal priority relative to other diverters.
Historical production data for these supplies from 2005 through 2024 are summarized in Table 6 and the City’s existing and planned water supplies are described in the sections below. 21 Therefore, recognized and governed under California’s surface water rights frameworks.
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2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 (a) 2022 2023 2024 910 910 910 910 910 910 910 910 910 910 910 910 910 910 910 910 750 910 910 910 471 503 500 473 439 436 482 535 569 351 344 343 390 397 394 418 359 339 326 363 471 503 500 473 439 436 482 535 569 351 344 343 390 397 394 418 359 339 326 363 Abbreviations:
"MGY" = million gallons per year
"City" = City of Cloverdale
"SWRCB" = California State Water Resources Control Board Notes:
(a)
(b)
(c)
Reference:
1. Water Supply Source
Historical Water Supply (c)
Table 6
Historical Water Supply for the City of Cloverdale Service Area Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Cloverdale, 2025b. Water Treatment Plant Production Data, provided by the City of Cloverdale on 19 June 2025.
Historical Water Supply
Surface Water Entitlements (b)
Historical Annual Water Supply (MGY)
Historical water supply values assumed equal to historical water demand. Historical water demands from 2005-2024 per per Reference 1.
The 2021 Surface Water Entitlement is adjusted to 750 MGY, reflecting curtailments and Health & Safety standards from 8/2/2021 to 10/21/2021. Outside of that period, proportional entitlements were assumed. These curtailments were implemented as part of system-wide regulatory actions affecting multiple Russian River rightsholders.
The City holds pre-1914 rights to divert water from Russian River Underflows, exercised via use of shallow wells located adjacent to the Russian River. This table reflects the full claimed entitlement of these rights - see SWRCB Statement ID S014237 for details. The City holds additional rights to divert from Big Sulphur Creek not included in this table. 0 100
200
300
400
500
600
700
800
900
1,000
2005200620072008200920102011201220132014201520162017201820192020 2021 (a)
202220232024
Historical Annual Water Supply (MG)
Historical Water Supply for the City's Service Area
Historical Water Supply Surface Water Entitlements (b)
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Identification of Water Supply Rights
Pursuant to CWC §10910(d)(1), CGC §66473.7(d), and CGC §66473.7(g), a WSA/WSV is required to include identification of all water supply entitlements, water rights, and water service contracts relevant to the identified water supply for the Proposed Project.
The City of Cloverdale meets its municipal water demand exclusively through well extraction for water supplies recognized as “Russian River underflow” – water that is underground but under the direct influence of the surface water of the Russian River and flows through the alluvial aquifer beneath the riverbed. Although extracted via the wells, this underflow is legally classified as surface water for water rights purposes due to its direct and immediate connection to the river’s flow22. Consistent with these regulatory classifications, this WSA/WSV includes a summary of the City’s surface water supply sources in its service area as detailed in the 2020 UWMP. Given that the supply source described herein is currently available to the City, the elements described in CGC §66473.7(d) are not included in this WSA/WSV.
Local Surface Water
6.2.1 Water Rights
As shown on Figure 3, the Russian River Watershed (Watershed) covers approximately 1,500 square miles across Mendocino and Sonoma Counties in the California Northern Coast Ranges.
The majority rainfed Russian River runs approximately 110 miles and has an average annual discharge of roughly 500,000 MG (Cloverdale, 2021). The river is dammed in two locations, creating Lake Mendocino – northeast of Ukiah on the East Fork Russian River, upstream of Cloverdale – and Lake Sonoma that feeds the Dry Creek tributary downstream of Cloverdale.
Flows in the Watershed have also been supplemented by Pacific Gas & Electric Company’s (PG&E) PVP which captures and diverts water from the Eel River into the Watershed – specifically into the East Fork Russian River above Lake Mendocino - for hydropower generation. PVP was opened in 1908 by PG&E and has played a critical role in providing water supplies for irrigation and municipal uses across the Watershed beyond its primary hydropower functions. PG&E has petitioned to decommission the PVP which may alter water available in the Watershed, as discussed in Section 7.2.
Cloverdale Water Rights
The City claims some of the oldest water rights in the Watershed, as follows (Cloverdale, 2021):
• A pre-1914 appropriative water right to the Russian River in the amount of at least 2.5 million gallons per day (MGD) (910 MGY), based on recent use, with a priority of 1884 and the right to further expand that use; and
• A pre-1914 appropriative right to divert water from Big Sulfur Creek in the amount of 125 cubic feet per second (cfs), equivalent to 24,000 MGY, with a priority of 189523. 22 See russianriverwaterforum.org/wp/wp-content/uploads/4-Water-rights-brief-Russian-River.pdf for more details. 23 This water right has not been included with the supply estimates contained in this WSA/WSV.
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On-Site Water Rights
As part of its Site acquisition, ELC will inherit several appropriative water rights designated under SWRCB License IDs L004520, L005931, L008557, and Permit ID P02055224. Table 7 summarizes the key characteristics, sources, and allowable uses associated with each right. Like Cloverdale, these rights authorize extractions from the Russian River underflows.
In addition to these licensed and permitted rights, the Site’s proximity and direct hydrologic connection to the Russian River likely confer riparian rights for certain parcels25. While there is no known history of riparian water use on the site, these rights may still exist and could potentially be exercised in the future.
ELC is evaluating the feasibility of utilizing its appropriative rights and, if applicable, any riparian rights, to support non-potable uses such as landscape irrigation or fire protection, consistent with their legal purposes of use. Together, these rights could provide up to approximately 19.5 MGY and 471 MGY, subject to SWRCB review and confirmation of allowable conditions. 24 These rights, which authorize diversions from Russian River underflows via existing wells, are still reflected under previous ownership in the SWRCB’s databases and have not yet been formally transferred to the current holder. 25 Riparian rights are a form of water right automatically attached to land contiguous to a natural watercourse, allowing reasonable use of water on that land without separate permitting, provided the use remains consistent with state law and does not injure other users.
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Path: X:\C40214.01\Maps\EsmeraldaFigures.aprx
Legend
Local Surface
Water Features
Esmeralda Land Company Mixed-Use
Development Project
City of Cloverdale, CA
November 2025
EKI C40214.01
Figure 3
Abbreviations
Proposed Project= Esmeralda Alexander Valley Resort
Notes
1. All locations are approximate.
Sources
1. Proposed Project boundary provided by Esmeralda Land Company on 15 May 2025.
2. Watershed boundary downloaded from the U.S. Department of Agriculture's GIS database, obtained 22 May 2025.
3. Basemap is ESRI's ArcGIS Online world aerial map, obtained 13 November 2025.
Russian River
0 2 4 8
Miles
Proposed Project Boundary
City of Cloverdale Service
Area
Russian River Watershed
Russian River
Proposed Project Site
Sonoma County
Mendocino County
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6.2.2 Water System
The City diverts water from the Russian River via the use of shallow extraction wellslocated along the west bank of the Russian River near its Water Treatment Plant (WTP), approximately 1/4-mile north of the East First Street (Crocker Road) Bridge. Water for the City is provided from seven such wells. Under normal operating conditions, the City does not run all seven wells simultaneously, allowing for well rotation and preventive maintenance to extend the operational life of each facility. However, during periods of lower subsurface underflow elevations, which typically coincides with periods of peak seasonal demand, the effective production capacity of the wells can be reduced due to air entrainment in the intake zone.
To address this condition, the City installed a de-aeration system designed to maintain or restore well performance during low flow periods in the Russian River. Additionally, the City has taken measures to reduce the maximum day demand by instituting water conservation measures during the peak water demand months.
The City’s WTP was constructed and put into service in 1996. Raw water from the City’s well field conveyed to the WTP where it is treated with the following processes (Cloverdale, 2021):
• Chemical injection of aluminum sulfate;
• Static mixer (baffled) for rapid mixing and coagulation; • Flow through upflow adsorption clarifier for solids removal; • Filtration through mixed media gravity filters;
• Post-disinfection by gas chlorination treatment; and
• Chemical injection of caustic (NaOH) for corrosion control.
As described in its 2020 UWMP Update, Cloverdale’s storage and distribution facilities include a piping network and fire hydrants, pumps, and reservoirs for three designated pressure zones across its service area. “Zone 1” is the main pressure zone and serves roughly 2,000 connections, accounting for about 67% of the water demand for the entire system. Zone 1 has approximately
2.5 MG of storage capacity and is served directly from the WTP. “Zone 2” serves about 350 connections and accounts for approximately 13% of the City’s water demand. Zone 2 includes
1.25 MG of storage and is served by Zone 1. “Zone 3” serves approximately 600 connections or about 20% of the City’s demand. Zone 3 includes 1.25 MG of storage and is fed by water from Zone 1.
Transfer pump station upgrades are planned to increase the City’s use of water supply source water under its existing water right as buildout and development occurs to ensure capacity to meet demand. In 2022, as part of its Urban and Multi-benefit Drought Relief Grant Program, DWR awarded the City a $3M grant to reduce air entrainment and improve water supply efficiency and reliability. This funding is being used to replace and upgrade two aging supply wells that are prone to air entrainment. These upgrades will also include new above-ground systems that provide realtime water level information, enabling more precise control and stabilizing subsurface underflow levels even during low flow or peak demand conditions. These upgrades are expected to save approximately 13 MGY, reducing subsurface diversions from the Russian River. Design for the November 2025 Page 37 of 112 EKI C40214.01
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two replacement wells is now complete; construction is anticipated to begin in 2025 (Cloverdale, 2024). Additionally, in 2025, the City plans to install a new well in its existing well field to improve production reliability and to allow for more operational flexibility with the existing, aging wells (Cloverdale 2021).
Additional projects are being planned or under consideration by the City as part of its Water Resiliency Program, see Appendix D. Key priority areas identified by the City include new domestic supply wells, recycled water systems, storage infrastructure, leak detection programs, and potential new water rights acquisitions (West Yost, 2025).
6.2.3 Water Quality
The water quality of the Russian River and its tributaries have been monitored by the North Coast Regional Water Quality Control Board (RWQCB) and other agencies since the 1970s. Due to elevated levels of sedimentation, pathogens, mercury, and temperature, several waterbodies in the Russian River Watershed have been designated as an impaired water body under Section 303(d) of the Clean Water Act26. These impairments can potentially affect the availability and usability of surface water for municipal supply, recreational use, and ecological health.
However, Cloverdale’s drinking water supply remains relatively insulated from these challenges because the City relies on underflow from the Russian River, which benefits from natural filtration processes, and the robust treatment protocols at the WTP, which ensure that delivered water meets all state and federal drinking water standards.
In addition to regulatory oversight by the RWQCB, the Russian River watershed is managed through collaborative efforts led by the Russian River Watershed Association (RRWA), a coalition of 11 local cities, counties, and special districts, including Cloverdale. Since its formation in 2003, the RRWA has coordinated regional initiatives focused on water quality improvement, watershed protection, and sustainable water resource management. As a participating member, Cloverdale contributes to and benefits from these collective efforts, helping to safeguard water quality and ensure long-term reliability and accessibility of water supplies for municipal and other uses (Cloverdale, 2021; Cloverdale, 2024).
Groundwater Use
Pursuant to CWC §10910(f)(3) and CGC §66473.7(2)(A), Cloverdale (and the Site) rely exclusively on recognized surface water from the Russian River, although it is extracted through wells from underflows. Accordingly, Cloverdale does not currently use groundwater to meet its municipal water demands. As such, no groundwater extraction is planned or anticipated to support the Proposed Project
Neither the City nor ELC expects to extract groundwater now or in the future to serve the Proposed Project. The Proposed Project’s demands will be met through the City’s existing and planned surface water supplies, consistent with current operations and infrastructure. Where feasible, and as systems are developed, non-potable sources – including on-Site water rights, recycled water, greywater reuse, and stormwater capture – will be used to meet landscape and 26 See waterboards.ca.gov/northcoast/water_issues/programs/tmdls/russian_river for more details.
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other discretionary demands, further reducing reliance on the City’s potable water system. This approach aligns with the City’s long-standing water management practices and avoids placing additional stress on local groundwater resources.
Total Projected Potable Supply in Normal, Single Dry, and Multiple Dry Years As described above, Cloverdale relies solely on the underflow of the Russian River, accessed under the City’s longstanding pre-1914 senior water right. Historical supply data from 2005 through 2024, along with the City’s surface water entitlement of 910 MGY, are presented in Table 627. The City’s projected supplies appear sufficient to meet anticipated demands in normal years, inclusive of the Proposed Project (see Table 8).
Chapter 7 of Cloverdale’s 2020 UWMP evaluates the long-term reliability of its water supplies under normal, single-dry, and multiple-dry hydrologic conditions. Based on this evaluation - and supported by the City’s senior pre-1914 right – Cloverdale’s water supplies are considered highly reliable in normal years (Cloverdale, 2021).
For dry-year analysis, the 2020 UWMP used the 2012-2016 drought period, which represented the most severe recent drought on record at that time. Specifically, 2016 – the year with the lowest recorded supply and demand – was used to represent single-dry year conditions, while multiple-dry year conditions were modeled by extending the hydrologic and operational patterns observed from 2014 to 2016 for two additional years. This approach produced a five-year drought simulation reflecting prolonged critically dry conditions, under which the City could still exercise its senior right but would likely experience reduced production efficiency and lower per-capita water availability.
During the 2012-2016 drought, the City implemented regional and statewide conservation measures to temporarily reduce demands. Consistent with that history, the 2020 UWMP assumes proportional short-term demand reductions (not actual supply losses) to test system resilience. These modeled “shortfalls” represent planning-level adjustments such as those that might be required under statewide emergency drought declarations.
This conservative methodology provides a margin of safety in evaluating long-term reliability.
Consistent with the 2020 UWMP28, this WSA/WSV assumes the following:
- Single-dry year water supply around 89% to 90% of corresponding projected demands (equivalent to supply “shortfalls” of 10-11%29), as shown in Table 9; and - Multiple-dry year water supply between 89% and 93% of corresponding projected demands (shortfalls of 7-11%29), as shown in Table 10.
Additional analyses presented in Section 467 of this WSA/WSV evaluates potential future risks, such as decommissioning of the PVP and evolving drought conditions, beyond those incorporated in the 2020 UWMP.
27 Does not include separate diversion entitlements to Big Sulfur Creek. 28 Note that the temporary curtailment in late 2021 reduced the City’s total annual water availability by approximately 18%, aligning with these 2020 UWMP dry year assumptions. 29 In this context, shortfalls refer to the difference between dry year impacted water supplies and corresponding demands, not percentage of average supplies as shown in Table 7-3 of 2020 UWMP.
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Projected Normal Year Water Supply and Demand (MGY)
2025 2030 2035 2040 2045
Surface Water Entitlements (a) 910 910 910 910 910
Normal Year Supply (b) 910 910 910 910 910
City Demand Inclusive of Proposed Project 532 611 639 659 676 City 2020 UWMP Water Demand (c) 532 565 570 583 600
Proposed Project Demand (d) 0 46 69 76 76
Supply Shortfall (% demand) None None None None None
Abbreviations:
"City" = City of Cloverdale
"gpcd" = gallons per capita per day
"MGY" = million gallons per year "UWMP" = Urban Water Management Plan "WSA" = Water Supply Assessment
"WSV" = Water Supply Verification
Table 8
Projected Normal Year Water Supply and Demand
Water Demand and Supply
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California "Proposed Project" = Esmeralda Land Company
Mixed-Use Development Project
"SWRCB" = California State Water Resources Control
Board
0 100
200
300
400
500
600
700
800
900
1,000
2025 2030 2035 2040 2045
Projected Water Supply and
Demand (MG)
Projected Normal Year Water Supply and Demand
City Demand Inclusive of Proposed Project Surface Water Entitlements (a) Normal Year Supply (b)
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Table 8
Projected Normal Year Water Supply and Demand
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Notes:
(a)
(b)
(c)
(d)
Reference:
1. Cloverdale, 2021. 2020 Urban Water Management Plan for the City of Cloverdale, prepared by Woodard & Curran, dated May 2021.
Projected supply is assumed equal to the City’s pre-1914 water rights on the Russian River, which is an entitlement of up to 910 MGY. This projected supply value for normal hydrologic years differ from what is presented in the 2020 UWMPs, which estimate a normal year supply equal to projected demand.
The City’s 2020 UWMP did not provide estimates for projected water demands in 2045. For purposes of this WSA/WSV, 2045 demand values were estimated by assuming an average growth rate in population from 2025 to 2040 to estimate a 2045 population value of 14,061. A gpcd of 117 was applied to the 2045 population projection to estimate an annual projected water use of 600 MGY, consistent with the methodology followed in the 2020 UWMP. The City's 2020 UWMP demands are inclusive of the Baumgardner Ranch Development Project, an approximately 300 housing unit development over 20 acres, which is incorporated into the City's latest growth and water demand projections per Reference 1.
The City holds pre-1914 rights to divert water from Russian River Underflows, exercised via use of shallow wells located adjacent to the Russian River. This table reflects the full claimed entitlement of these rights - see SWRCB Statement ID S014237 for details. The City holds additional rights to divert from Big Sulphur Creek not included in this table.
As discussed in Section 5 of the WSA/WSV, the Proposed Project demands are not included within the 2020 UWMP and are, therefore, considered additive to City demands.
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Projected Single Dry Year Water Supply and Demand (MGY) 2025 2030 2035 2040 2045
Surface Water Entitlements (a) 910 910 910 910 910
Single Dry Year Supply (b) 477 547 571 591 606
City Demand Inclusive of Proposed Project 532 611 639 659 676 City 2020 UWMP Water Demand (c) 532 565 570 583 600
Proposed Project Demand (d) 0 46 69 76 76
Supply Shortfall (% demand) 10% 10% 11% 10% 10%
Abbreviations:
"City" = City of Cloverdale
"gpcd" = gallons per capita per day
"MGY" = million gallons per year "UWMP" = Urban Water Management Plan "WSA" = Water Supply Assessment
"WSV" = Water Supply Verification
Table 9
Projected Single Dry Year Water Supply and Demand
Water Demand and Supply
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California "SWRCB" = California State Water Resources Control
Board
"Proposed Project" = Esmeralda Land Company
Mixed-Use Development Project
0 100
200
300
400
500
600
700
800
900
1,000
2025 2030 2035 2040 2045
Projected Water Supply and
Demand (MG)
Projected Single Dry Year Water Supply and Demand
City Demand Inclusive of Proposed Project Single Dry Year Supply (b) Surface Water Entitlements (a)
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Table 9
Projected Single Dry Year Water Supply and Demand
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Notes:
(a)
(b)
(c)
(d)
Reference:
1. Cloverdale, 2021. 2020 Urban Water Management Plan for the City of Cloverdale, prepared by Woodard & Curran, dated May 2021.
The City holds pre-1914 rights to divert water from Russian River Underflows, exercised via use of shallow wells located adjacent to the Russian River. This table reflects the full claimed entitlement of these rights - see SWRCB Statement ID S014237 for details. The City holds additional rights to divert from Big Sulphur Creek not included in this table.
Water supply available to the City during single dry years is based on the dry year supply projections presented in Reference 1. Although the City has pre-1914 water rights on the Russian River with an entitlement of up to 910 MGY, the UWMP conservatively assumes supply shortfalls that range from 10% to 11% in 2025-2040 in single dry years. In this context, shortfalls refer to the difference between dry year impacted water supplies and corresponding demands, not the percentage reduction from average supplies as shown in Table 7-3 of the 2020 UWMP. This 10-11% supply-demand shortfall indicates that while the City can use its senior water right, it would trigger its WSCP and implement demand management measures and conservation efforts to reduce demands, thus decreasing the necessary supply. For consistency with the 2020 UWMP, it is assumed the City will face similar supply shortfall percentages with the added Proposed Project demand.
The City’s 2020 UWMP did not provide estimates for projected water demands in 2045. For purposes of this WSA/WSV, 2045 demand values were estimated by assuming an average growth rate in population from 2025 to 2040 to estimate a 2045 population value of 14,061. A gpcd of 117 was applied to the 2045 population projection to estimate an annual projected water use of 600 MGY, consistent with the methodology followed in the 2020 UWMP.
The City's 2020 UWMP demands are inclusive of the Baumgardner Ranch Development Project, an approximately 300 housing unit development over 20 acres, which is incorporated into the City's latest growth and water demand projections per Reference 1.
As discussed in Section 5 of the WSA/WSV, the Proposed Project demands are not included within the 2020 UWMP and are, therefore, considered additive to City demands.
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2025 2030 2035 2040 2045
Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Surface Water Entitlements (a) 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 750 Multiple Dry Year Supply (b) 495 481 477 477 477 568 553 547 547 547 594 577 571 571 571 612 597 591 591 591 629 612 606 606 606 City Demand Inclusive of Proposed Project 532 532 532 532 532 611 611 611 611 611 639 639 639 639 639 659 659 659 659 659 676 676 676 676 676 City 2020 UWMP Water Demand (c) 532 532 532 532 532 565 565 565 565 565 570 570 570 570 570 583 583 583 583 583 600 600 600 600 600 Proposed Project Demand (d) 0 0 0 0 0 46 46 46 46 46 69 69 69 69 69 76 76 76 76 76 76 76 76 76 76 Supply Shortfall (% demand) 7.0% 10% 10% 10% 10% 7.1% 10% 10% 10% 10% 7.0% 10% 11% 11% 11% 7.0% 9.4% 10% 10% 10% 7.0% 10% 10% 10% 10% Abbreviations:
"City" = City of Cloverdale "WSCP" = Water Shortage Contingency Plan "gpcd" = gallons per capita per day "WSV" = Water Supply Verification "MGY" = million gallons per year
"Proposed Project" = Esmeralda Land Company Mixed-Use Development Project "UWMP" = Urban Water Management Plan
"WSA" = Water Supply Assessment
Water Demand and Supply
Table 10
Projected Multiple Dry Year Water Supply and Demand
Projected Multiple Dry Water Supply and Demand (MGY)
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California 0 100
200
300
400
500
600
700
800
Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Year 1 Year 2 Year 3 Year 4 Year 5 Projected Water Supply and Demand (MG)
Projected Multiple Dry Year Water Supply and Demand
City Demand Inclusive of Proposed Project Multiple Dry Year Supply (b) Surface Water Entitlements (a) November 2025 Page 44 of 112 EKI C40214.01
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Table 10
Projected Multiple Dry Year Water Supply and Demand
Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Notes:
(a)
(b)
(c)
(d)
Reference:
1. Cloverdale, 2021. 2020 Urban Water Management Plan for the City of Cloverdale, prepared by Woodard & Curran, dated May 2021.
Water supply available to the City during multiple dry years is based on the dry year supply projections presented in Reference 1. Although the City has pre-1914 water rights on the Russian River with an entitlement of up to 910 MGY, the UWMP conservatively assumes supply shortfalls that range from 7% to 11% in 2025-2040 in multiple dry years. In this context, shortfalls refer to the difference between dry year impacted water supplies and corresponding demands, not the percentage reduction from average supplies as shown in Table 7-3 of the 2020 UWMP. This 7-11% supply-demand shortfall indicates that while the City can use its senior water right, it would trigger its WSCP and implement demand management measures and conservation efforts to reduce demands, thus decreasing the necessary supply. For consistency with the 2020 UWMP, it is assumed the City will face similar supply shortfall percentages with the added Proposed Project demand.
The City’s 2020 UWMP did not provide estimates for projected water demands in 2045. For purposes of this WSA/WSV, 2045 demand values were estimated by assuming an average growth rate in population from 2025 to 2040 to estimate a 2045 population value of 14,061. A gpcd of 117 was applied to the 2045 population projection to estimate an annual projected water use of 600 MGY, consistent with the methodology followed in the 2020 UWMP. The City's 2020 UWMP demands are inclusive of the Baumgardner Ranch Development Project, an approximately 300 housing unit development over 20 acres, which is incorporated into the City's latest growth and water demand projections per Reference 1.
As discussed in Section 5 of the WSA/WSV, the Proposed Project demands are not included within the 2020 UWMP and are, therefore, considered additive to City demands.
The City holds pre-1914 rights to divert water from Russian River Underflows, exercised via use of shallow wells located adjacent to the Russian River. This table reflects a 18% reduction account for potential curtailments similar to those enacted in 2021. During that period, pre-1914 Russian River water rights were curtailed from August 2 to October 21, with Health & Safety allocations set at 55 gpcd for summer months and full entitlement assumed for the remainder of the year. The adjusted values reflect these conditions.
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7 WATER SUPPLY RELIABILITY AND CONSTRAINTS
This section builds upon the water supplies and reliability estimates from the 2020 UWMP that were identified in Section 6 by qualitatively evaluating them in the context of future hydrologic variability, regulatory uncertainty, and infrastructure considerations. While not a required element of the WSA/WSV, this discussion provides additional insight given: (1) the timing of this WSA/WSV relative to Cloverdale’s 2020 UWMP Update (see Section 1.2); (2) the extreme drought conditions affecting the Russian River Watershed (Watershed) in 2021-2022 and Cloverdale’s associated response; and (3) the planned decommissioning of PG&E’s PVP, which is expected to reduce imported flows from the Eel River to the Watershed.
Hydrologic Variability and Drought Risk
The Watershed encompasses approximately 1,500 square miles within California’s North Coast Region, which is characterized by a Mediterranean climate with distinct wet and dry seasons and highly variable precipitation patterns. Approximately 90-95% of annual precipitation occurs between October and May (CW3E, n.d.), often concentrated in a few major storm events each year. Unlike other California watersheds with higher-elevation headwaters and snowpack-driven runoff, most inflow to the Russian River system occurs as direct rainfall runoff. The Watershed is generally divided into the “Upper Watershed” portion, extending from the headwaters near Redwood and Potter Valleys downstream to Healdsburg (including Cloverdale), and the “Lower Watershed” portion, which continues from Healdsburg to the river’s terminus at the Pacific Ocean near Jenner. This distinction is hydrologically and operationally significant, as major reservoirs (e.g., Lake Mendocino and Lake Sonoma) and key tributaries primarily influence the Upper Watershed, while the Lower Watershed is more directly affected by downstream flow management, instream flow requirements, and estuarine conditions near the coast (Sonoma Water, 2022).
Available long-term data highlight the high degree of hydrologic variability within the Watershed.
Accumulated precipitation records from the National Weather Service (NWS) station near Ukiah30 (Figure 4), beginning in January 1970, indicate an average annual precipitation of approximately 36.4 inches in the Upper Watershed. These data also show a mild downward trend of roughly 0.05 inches per year. During extreme drought years, total precipitation dropped to only 40-60% of the long-term average.
Similarly, U.S. Geological Survey (USGS) discharge data for the Russian River near Cloverdale31 (Figure 5), also shown from 1970, illustrate pronounced seasonal variability consistent with the region’s Mediterranean climate. Average wet-season (October to May) flows were approximately 3,600 cubic feet per second (cfs), while dry-season (June to September) flows averaged about 148 cfs. Over this period, peak wet-season flows exhibited a clear decline of about –24 cfs per year, whereas dry-season flows showed no discernible trend. The latter stability likely reflects regulated releases from Lake Mendocino to maintain minimum instream flow requirements, 30 Station ID “UKH”, precipitation data available at California Data Exchange Center (CDEC). Data provided through September 2025.
31 USGS Station 11463000, available on National Water Information System web interface. Data provided as mean daily flow rate.
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while the reduction in wet-season peaks suggests that even modest decreases in precipitation can produce impacts on river flow volumes.
To further illustrate recent hydrologic variability within the Watershed, Table 12 presents Full Natural Flow (FNF) data for the Russian River beginning in 2021. The FNF represents the estimated natural flow in the absence of human development or operational influences – thereby excluding factors such as PVP imports, reservoir releases, and other management actions. These data therefore provide a useful indicator of climate-driven hydrologic variability. The monthly and annual fluctuations shown underscore this variability in the Watershed and clearly reflect the effects of the severe drought conditions in 2021 and 2022 on natural Russian River flows.
7.1.1 Watershed Drought Conditions
As reflected in the preceding data, the Watershed has experienced multiple severe droughts over its recorded history. Notable events include the 1976–1977 drought (approximately 38% of normal precipitation and 16% of average streamflow), the 2012–2016 drought (56% of normal precipitation and 20% of streamflow), and the 2020–2022 drought (52% of normal precipitation and 24% of streamflow). The latter two droughts were particularly severe, as elevated temperatures increased evapotranspiration losses and further reduced the streamflow available for supply and environmental needs (CW3E, 2018). The 12-month period from February 2013 through January 2014 remains the driest on record for the Watershed, while 2021–2022 ranks as the second driest period occurring less than a decade later, in contrast to the roughly 35-year interval between earlier major droughts (Sonoma Water, 2022).
These extreme drought conditions also resulted in historically low storage levels in the Watershed’s two primary reservoirs, Lake Mendocino and Lake Sonoma (CW3E, n.d.). Both reservoirs are essential to meeting municipal, agricultural, and instream flow needs across the Upper and Lower Watersheds. To conserve remaining storage during these droughts, reservoir releases and downstream flows were reduced to some of the lowest levels observed since the initiation of flow regulations (CW3E, 2018).
Although not specific to the Watershed, DWR also maintains Water Year Hydrologic Classification Indices for the Sacramento Valley32, which serve as a useful indicator of broader Northern California hydrologic conditions from 1906 to the present. Over this historical record, individual “Dry” and “Critically Dry” years account for approximately 33% of all years, while multi-year sequences of these classifications – representative of drought conditions – occurred about 25% of that time. Since 2000, roughly 44% of years have been classified as “Dry” or “Critically Dry”, all occurring as part of multi-year drought sequences. These trends clearly suggest an increase in the frequency and persistence of drought conditions across Northern California.
Looking ahead, future drought conditions are projected to follow a similar pattern to the more recent periods, that is, extreme dry periods punctuated by very wet years. This emerging “climate whiplash” phenomenon is expected to intensify, even if long-term average precipitation remains relatively unchanged (CW3E, 2018). The increasing frequency and magnitude of these hydrologic 32 DWR Chronological Reconstructed Sacramento and San Joaquin Valley Water Year Hydrologic Classification Indices, available on CDEC from 1906 to 2024.
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extremes pose significant challenges for water supply reliability, reservoir operations, and environmental management (e.g., maintaining in-stream requirements). It is generally understood that addressing these challenges will require adaptive management strategies capable of responding to rapid transitions between scarcity and abundance while sustaining environmental flows and meeting diverse water demands throughout the Watershed. The City has acknowledged as much and is developing its own Water Resiliency Program (West Yost, 2025; Appendix D).
7.1.2 Sub-Surface Flow Nexus
It should be noted that the surface flow records presented above do not capture changes in the Russian River underflow (subsurface flows) from which Cloverdale exercises its water rights, as described in Section 6 and further detailed below.
To improve understanding of surface water management and its nexus with subsurface flow and local groundwater conditions, the USGS, in cooperation with the SWRCB and Sonoma Water, developed a digital three-dimensional Hydrogeologic Framework Model (HFM) of the Watershed (Cromwell, Sweetkind, Langenheim, & Ely, 2024). This model integrates geologic, hydrologic, and geophysical datasets, including well construction records, elevation mapping, and depth-towater measurements, of the Alexander Valley Groundwater Basin, which includes the Cloverdale Area (DWR Subbasin No. 1-054.02) and the Alexander Area (DWR Subbasin No. 1-054.01) Subbasins. Both are designated as “Very Low” priority basins under the DWR’s Sustainable Groundwater Management Act (SGMA) framework33 yet remain important for local water supply and surface water-groundwater interaction studies.
Appendix E of this WSA/WSV further examines findings from the HFM and other sources to evaluate interactions between surface and subsurface flow systems. This assessment helps clarify how Russian River flow conditions influence Cloverdale’s production wells, recognized as surface water-connected and therefore regulated under the SWRCB’s surface water rights framework.
Cloverdale maintains access to water through its shallow production wells, which extend roughly 65 feet below ground and tap the Russian River underflows within the alluvial sediments. These sediments store substantial water volumes, buffering the City’s subsurface supply from shortterm fluctuations in river flows; analyses indicate that only sustained changes in river flow over a 2-3+ month period meaningfully affect groundwater levels (USGS, 2024). When combined with the City’s water system of seven wells and surplus production capacity, this configuration provides operational flexibility and resiliency, ensuring continued water availability for municipal supply even under extended periods of reduced surface flow conditions. 33 As a result, these subbasins are not subject to SGMA’s groundwater sustainability planning requirements. Given this designation, and the fact that the City does not actively rely on groundwater for municipal supply, this WSA/WSV does not address subbasin safe yield, historical pumping trends, or conditions related to overdraft, as those requirements do not apply to these groundwater basins. In short, the subbasins underlying Cloverdale are not subject to the SGMA planning and management obligations that apply in higher-priority basins elsewhere in California (e.g., the Central Valley).
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PVP Decommissioning
PG&E is decommissioning its Potter Valley Project hydropower facilities34 primarily due to economic considerations (PG&E, n.d.). Historically, the PVP has diverted water from the Eel River through a trans-basin tunnel into the East Fork Russian River, where a portion of the diverted flow is used by the Potter Valley Irrigation District (PVID), and the remainder continues to Lake Mendocino35. These imported flows have played a critical role in supplementing the highly variable, rainfall-driven hydrology of the Watershed. Stored water in Lake Mendocino has been managed and released to support downstream diversions, municipal and agricultural demands, and instream flow requirements.
Cloverdale is located downstream of these operations, and the City’s water supply is derived from its own senior water rights and wells hydraulically connected to the Russian River underflow. The planned decommissioning of the PVP has significant implications for regional water reliability across the Upper Watershed. Historically, imported Eel River flows have supplemented the Russian River system during extended dry periods, providing an important hydrologic buffer that sustained baseflows, reservoir storage and instream habitat conditions. These imports have helped stabilize municipal, agricultural, and environmental water supplies, particularly during late summer and early fall when natural runoff is minimal. While its senior water rights provide meaningful resilience, the City is exploring diversification of its water supply sources to minimize potential water shortage conditions (West Yost, 2025). The Project Proponent will coordinate with the City, as appropriate, to support its efforts.
Accordingly, while Cloverdale’s senior water rights provide a strong legal and operational foundation, the City may still experience indirect impacts from regional hydrologic changes associated with the PVP’s decommissioning, warranting continued coordination with regional water management agencies to monitor and adapt to evolving conditions (PVAC, 2019a and 2019b). As such, the City is developing its own Water Resiliency Program (West Yost, 2025; Appendix D).
7.2.1 Timeline and Watershed Efforts
PG&E filed a “Notice of Withdrawal” with FERC on 25 January 2019, initiating the process to surrender its license and decommission the PVP. Following a multi-year consultation process with resource agencies and tribal representatives that began in late 2023, PG&E submitted its Final Surrender Application to FERC on 25 July 2025. That application proposes the removal of major PVP facilities, including Cape Horn Dam and Van Arsdale Reservoir, Scott Dam and Pillsbury Reservoir, as well as ancillary infrastructure such as the powerhouse and water conveyance tunnels. The “decommissioning process” is now anticipated to take two to three years(Huettl, 2024), during which PG&E will continue consulting with state resource agencies, tribal 34 PVP, initiated in 1908, captures water at Cape Horn Dam (Van Arsdale Reservoir) and Scott Dam (Lake Pillsbury) on the Eel River. It diverts water through a tunnel to a powerhouse on the Russian River principally for hydropower generation. In addition to power production, Potter Valley plays a critical role in providing essential water supplies 35 For agricultural irrigation and municipal uses across the Watershed. PVP is licensed by the Federal Energy Regulatory Commission (FERC), and the operating license (FERC Project No. 77) expired on April 14, 2022. Since then, Potter Valley has continued to operate under annual license extensions.
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representatives, and other stakeholders. An outcome from this decommissioning is restoration of the Eel River to a free-flowing state and improved fish passage, which would result in the cessation of water exported from the PVP into the Russian River. Current planning targets 2028 for commencement of facilities removal (PG&E, n.d.).
In response to the planned PVP decommissioning, regional partnerships have formed to support Watershed supplies, including the Russian River Water Forum (led by Sonoma Water) and the Eel-Russian Project Authority (ERPA), which includes the Inland Water & Power Commission of Mendocino County (IWPC). ERPA has proposed continuing water diversions into the Russian River through new facilities while improving fish passage and is actively negotiating with PG&E regarding the potential transfer of PVP diversion water rights, facilities, and lands (ERPA, n.d.).
The feasibility and implementation of the so-called “New Eel-Russian Facility” (NERF) are outside the scope of this WSA/WSV, and all subsequent water supply projections herein conservatively assume a “no alternative” scenario. Under the proposed NERF alternative, Lake Mendocino could continue receiving Eel River flows, though likely at lower volumes and subject to enhanced environmental diversion requirements compared with historical PVP operations.
7.2.2 No Alternative Scenario
Existing modeling and analyses of a PVP decommissioning “no alternative” scenario assumes full removal of Scott Dam, Cape Horn Dam, and all PVP diversion infrastructure, effectively eliminating flows from the Eel River into the Russian River Watershed (PG&E, n.d.; PVAC, 2019a and 2019b). Based on May and September 2019 studies by the Potter Valley Ad Hoc Committee36, the following conditions are projected:
• Impacts to East Fork Russian River and Lake Mendocino o Average inflows to Lake Mendocino projected to decrease by approximately 44% compared with current conditions supplemented by PVP diversions. o Lake Mendocino’s likelihood of full depletion increases significantly, to nearly every year compared with once every 53 years under historical conditions. o Minimum storage frequently falls below levels needed to sustain consistent releases for both environmental flows and water supply purposes. o Summer and fall flows in the Russian River are projected to drop sharply, sometimes to critically low levels, due to insufficient reservoir capacity to provide compensatory releases.
• Operational Implications
o Without PVP diversions, reliability for summer and fall municipal, agricultural, and environmental water demands will likely be impacted.
o Flows in the Upper Watershed (Forks, Hopland, Cloverdale, Healdsburg) will be consistently below baseline (existing) during summer and fall, driven by reduced reservoir storage and the absence of Eel River inflows. 36 The purpose of the Ad Hoc Committee is to realize a “two-basin” (Eel and Russian River) solution for the PVP consistent with the Ad Hoc Committee’s co-equal goals and principles, for more information see:
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o Peak winter flows may exceed baseline during wetter years due to unimpaired inflows; however, these are insufficient to offset dry season deficits. o Projected drier springs and reduced snowmelt are expected to further exacerbate summer and fall flow reductions.
In the absence of continued Eel River diversions, the Upper Watershed is projected to experience more frequent dry and low flow conditions37. Currently, surface flows in the vicinity of Cloverdale – especially during late-summer and autumn months - are largely maintained by mandatory releases from Lake Mendocino, which are implemented to support for in-stream flows for fisheries management, downstream ecological needs, and downstream municipal and agricultural uses.
Under a no-diversion scenario, the most significant reduction in water availability would be expected to affect primary users directly dependent on PVP diversions and Lake Mendocino storage, including PVID and other municipal and agricultural stakeholders in the Upper Watershed. Cloverdale, located farther downstream and relying on subsurface underflows of the Russian River under senior pre-1914 water right, is not expected to experience immediate or direct supply reductions, although regional hydrologic conditions could influence long-term system operations and management priorities38.
7.2.3 Anticipated Cloverdale Impacts
As detailed in Section 6, Cloverdale relies on Russian River underflows to exercise its pre-1914 water rights and to provide its municipal water supply. While the City is not directly dependent on PVP diversions, it could experience secondary impacts from changes in watershed hydrology if PVP diversions from the Eel River are permanently ceased. The following summarizes these potential effects:
• Surface flows near Cloverdale are presently sustained in part by mandatory releases from Lake Mendocino to support downstream environmental flows and water uses, especially in late-summer and autumn months when natural flows are minimal. Under reduced inflow conditions following PVP decommissioning, these releases will likely occur less frequently or at lower volumes, resulting in decreased river stage levels and the potential for reduced recharge to the Russian River underflow in certain months and conditions. The extent and mechanisms of these interactions remain uncertain but are further examined in Appendix E. • The City’s pre-1914 surface water rights provide meaningful protection against Watershed supply reductions – as detailed in the following section - allowing continued diversion from Russian River underflows hydraulically connected to surface flows. Cloverdale’s minimum available supply is governed by both natural hydrologic conditions and regulatory release requirements from Lake Mendocino. While reduced Eel River inflows could alter seasonal flow timing and magnitude, these changes are not anticipated to significantly affect the City’s 37 Cloverdale anticipates that the Potter Valley Project decommissioning may affect its water supplies. Per May 2019 “Model Simulation Report for Baseline Operations and Potter Valley Project Decommissioning – Scenario 3 Report Summary” prepared for the Potter Valley Project. 38 Does not apply to Cloverdale, as “100% of the water supply for [the City] is pumped from underflow of the Russian River” not directly originating from Lake Mendocino releases. Per 17 December 2014 “Beneficial Use of Water Stored in Lake Mendocino” Report, and as confirmed in City’s 2020 UWMP Update.
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long-term water supply reliability under current regulatory and operational frameworks. To address seasonal variations in water supply availability, the City is exploring other water supply sources to minimize potential water shortage conditions (West Yost, 2025). The Project Proponent will coordinate with the City, as appropriate, to support its efforts. • In its long-term supply planning, the City has conservatively projected that under dry-year conditions it may be able to divert approximately 90% of its average annual supply - reflecting an estimated 10% reduction in availability (Cloverdale, 2021). This assumption aligns with regional streamflow modeling and represents a reasonable planning benchmark in the absence of site-specific hydrologic modeling.
Regulatory Framework and Curtailment Considerations
Cloverdale holds a pre-1914 appropriative water right to Russian River underflows, established in 1884, as detailed in Section 6.2.1. This right has historically proven highly reliable, including during major droughts. However, during the extraordinary drought of 2021-2022, the SWRCB issued its first-ever mandatory curtailments in the Russian River Watershed, temporarily affecting even senior rights such as Cloverdale’s39. This section provides an overview of Cloverdale’s standing within the watershed, as well as the context and implications of recent curtailment events.
7.3.1 Seniority Overview
The SWRCB’s Electronic Water Rights Information Management System (eWRIMS) provides publicly available data on California water rights and claims. While pre-1914 appropriative rights, such as Cloverdale’s, are not directly administered by the SWRCB, eWRIMS records remain a useful reference for comparative analysis.
Under California Water Code Divisions 2 and 2.5, and consistent with long-standing case law, a senior water right holder is entitled to fully exercise their right before any junior right holder may divert, provided sufficient natural flow exists. A high-level review of eWRIMS data for the Russian River Watershed identifies approximately 47 actively used pre-1914 rights, including Cloverdale’s. Of these, only 12 report a “year of first use” (claimed priority) earlier than 1884.
As summarized in Table 13, the aggregate estimated use associated with more-senior or riparian40 rights totals roughly 8,800 AFY41, compared to approximately 155,000 AFY of reported uses42 associated with more-junior rights. This places Cloverdale among the most senior water 39 Via a 2 August 2021 SWRCB Order to cease diversions from the Russian River and reaffirmed in SWRCB Order WR 2021-0096, except for diversions to meet minimum water needs for health and human safety; followed a 21 April 2021 drought state of emergency in the Russian River Watershed declared by Governor Newsom. See waterboards.ca.gov/drought/russian_river for more details. 40 Under California water law, riparian rights generally have senior priority over appropriative rights, including those established before 1914. Riparian rights attach to land that physically borders a natural watercourse and allow the reasonable use of water on that land. 41 Acre-feet per year (AFY), equivalent to around 2,866 MGY. Cloverdale’s pre-1914 water right allows up to 910 MGY of water supply, for comparison. 42 Based on average water use reported to the SWRCB, does not necessarily indicate the maximum extent or entitlement of these rights and claims.
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rights holders in the Watershed, providing a generally advantageous position during times of reduced supply. Note these estimates exclude rights to store water for later use, such as those associated with Lake Mendocino and Lake Sonoma.
7.3.2 Hydrologic Context
Hydrologic data at the USGS Cloverdale gage suggests that annual flow volume in the Upper Watershed averages approximately 620,000 AFY under long-term conditions. During the 2021- 2022 drought, this total decreased to between 125,000 and 185,000 AFY, or roughly 20-30% of average.
In such critically dry conditions, or under potential flow changes following PVP decommissioning, junior right holders would, under law, be expected to forego diversions to allow senior rights such as Cloverdale’s to be exercised, assuming water is physically available. The specific process by which these priorities are enforced or verified is beyond the scope of this WSA/WSV but is administered by the SWRCB through curtailment orders and related drought response actions.
7.3.3 Curtailment Risks
During the extraordinary drought conditions of 2021, the SWRCB issued its first-ever mandatory curtailment affecting Cloverdale’s pre-1914 right43.
Beginning 2 August 2021, the City was initially limited to the state-defined minimum of 55 GPCD for health and human safety, as required under California Code of Regulations (CCR) Title 23, §875.2. Cloverdale was also required to report monthly diversions during this period. Shortly thereafter, on 10 September 2021, the SWRCB approved the City’s petition for additional supply44, authorizing up to 104 GPCD - comprising 70 GPCD for essential municipal and domestic uses and 34 GPCD for other critical public health and safety needs.
These curtailment measures remained in effect for 80 days, ending 21 October 2021. Although Cloverdale was not subject to further curtailments during the remainder of the drought emergency, the Watershed remained under the overarching SWRCB curtailment order, allowing the SWRCB to reimpose restrictions as hydrologic conditions warranted. The order was formally lifted on 29 March 2023 through Executive Order N-5-23. This remains the only instance to date where pre-1914 rights holders in the Upper Watershed were curtailed and unable to fully exercise their rights45. Even then, state provisions ensured a guaranteed minimum supply, and the City was successful in securing additional allocations beyond the minimum baseline.
As the City’s permanent population grows – including the expected addition of residents from the Proposed Project – the 55 GPCD health and safety entitlement will scale proportionally, ensuring that essential water needs continue to be met. At full buildout, the estimated 43 Via a 2 August 2021 SWRCB Order to cease diversions from the Russian River and reaffirmed in SWRCB Order WR 2021-0096, except for diversions to meet minimum water needs for health and human safety; followed a 21 April 2021 drought state of emergency in the Russian River Watershed declared by Governor Newsom. See waterboards.ca.gov/drought/russian_river for more details. 44 Pursuant to CCR Title 23, §878.1(b)(2). 45 Prior drought curtailments in 2014-2015 was limited to rights in the Russian River above Dry Creek confluence.
Later 2022 and 2023 curtailments only affected other rightsholders in the watershed.
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permanent population of the Proposed Project is approximately 1,565 residents, excluding transient resort guests. Based on current regulatory standards:
• At 55 GPCD, this population would be entitled to approximately 86,075 gallons per day, or
31.4 MGY (96.4 AFY) equivalent, roughly 64% of the Proposed Project’s total projected demand.
• With a similar SWRCB petition as granted in 2021, that increased the allocation to 104 GPCD, the entitlement could increase to 162,750 GPD (59.4 MGY equivalent), covering approximately 121% of the Proposed Project’s total projected indoor/potable demand, effectively creating a surplus supply that would be available to other City customers.
As outlined in Table 2, approximately 27 MGY of the Proposed Project demand is associated with “non-essential” uses such as landscape irrigation – uses that occur primarily in late summer and early autumn. These discretionary demands can be suspended during drought conditions, since the more junior On-Site water rights would be curtailed before any reductions in Cloverdale’s municipal supply – consistent with curtailments observed during the last drought. Furthermore, implementing additional conservation measures aligned with Cloverdale’s WSCP would further reduce potable demand and help meet minimum supply thresholds during emergency conditions46.
Together, CCR Title 23 provisions, SWRCB petition mechanisms, and Cloverdale’s drought response framework provide a robust structure for ensuring that the Proposed Project can maintain essential water supply even under the most restrictive scenarios. ELC will coordinate with the City, as needed, to support future SWRCB petitions, consistent with the City’s past success and regulatory authority. Importantly, Cloverdale’s senior pre-1914 water right remains a critical foundation of its long-term supply reliability, helping to safeguard essential water access for existing and future residents, even in periods of extreme drought.
Considerations for WSA/WSV Supply Projections
The City’s water supply projections are informed by a combination of historical hydrologic data, pre-1914 water rights, and system-specific infrastructure characteristics. While Russian River flows - particularly during late-summer and fall months - may be influenced by potential PVP decommissioning, extended drought, or regulatory curtailments, Cloverdale’s physical access to underflows through its shallow alluvial wells provides a resilient buffer against shorter-term flow variability. The City’s senior water rights, mandatory minimum releases, and redundant well system further support reliable municipal supply. To enhance this reliability going forward, the City is actively developing a Water Resiliency Program, which is intended to further secure and diversify its water supplies and facilities given variable hydrologic conditions (as shown in Appendix D). Combined with the projected 234 MGY difference between supplies available under Cloverdale’s rights and total system demands under nominal conditions (presented in 46 To meet demands, up to an additional 35% conservation may be needed beyond irrigated landscaping water uses to meet the health and safety allocations provided during extreme curtailment conditions. This roughly corresponds with the most stringent water conservation requirements and shortage response actions provided in Cloverdale’s WSCP. Appendix F provides corresponding response actions anticipated by the Proposed Project.
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Sections 5 and 6)47, these buffers indicate that Cloverdale is well-positioned to meet projected demands, including those of the Proposed Project, even under scenarios of reduced inflows, prolonged drought, or temporary curtailment events. It should be acknowledged, however, that certain months and hydrologic conditions may still present heightened stress on the water supply system, underscoring the importance of continued implementation of the City’s WSCP and Water Resiliency Program.
47 Though the City’s UWMP conservatively assumes supply shortfalls that range from 10% to 11% in 2025-2040 in single and multiple dry years. This shortfall is meant to indicate that Cloverdale can use its senior water right but would trigger its WSCP and implement demand management measures and conservation efforts to reduce demands thus decreasing the necessary supply.
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Abbreviation
"in" = inches
Notes
References
1. California Data Exchange Center, 2025a. Station UKH precipitation data, accessed 9 October 2025, (https://cdec.water.ca.gov/).
Figure 4
NWS Accumulated Precipitation Data for Russian River Watershed at Ukiah from January 1970 to Present Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California (a) Data missing for 1981-1983, 2007, and 2013.
"NWS" = National Weather Service
0 10
20 30
40 50
60 70
80 1970197219741976197819801982198419861988199019921994199619982000200220042006200820102012201420162018202020222024 Accumulated Precipitation (in)
NWS Accumulated Precipitation Data for Russian River Watershed at Ukiah November 2025 Page 56 of 112 EKI C40214.01
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Abbreviation
References
Figure 5
USGS Russian River Flow Data near Cloverdale from January 1970 to Present Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California "cfs" = cubic feet per second
1. United States Geological Survey. (n.d.). USGS station 11463000: Mean daily flow rate . National Water Information System, accessed 9 October 2025, (https://waterdata.usgs.gov/monitoring-location/USGS-11463000/). "USGS" = United States Geological Survey
0 2000
4000
6000
8000
10000
12000
1970197219741976197819801982198419861988199019921994199619982000200220042006200820102012201420162018202020222024 Flow Rates (cfs)
Min Max
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2022 930 157 68 205 42 0 0 0 0 0 14 1,281
2023 7,055 1,122 6,122 1,440 399 108 0 0 0 0 18 1,172
2024 3,590 7,370 3,642 1,006 341 61 0 0 0 0 3,065 4,466 2025 1,524 7,400 2,141 1,338 233 50 0 0 0 8 (a) (a)
Abbreviations:
"cfs" = cubic feet per second
Notes
References
Monthly Average FNF (cfs)
Table 11
Observed Full Natural Flow for the Russian River, 2021–2025 Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Jan Feb Dec
Year
1. California Data Exchange Center, 2025b. Full Natural Flow (FNF) data for the Russian River (2021–present). Accessed 15 October 2025. https://cdec.water.ca.gov/.
Mar Apr May Jun Jul Aug Sept Oct Nov
(a) Indicates no data available or insufficient valid measurements for that month. Indicates no data available for that month. Negative or suspect values from the source data have been reported as zero.
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Senior 2 64
Riparian 199 4,623
Junior 516 28,403
Senior 10 370
Riparian 348 3,738
Junior 817 126,388
Total (including City) 1,893 164,817
Abbreviations:
"AFY" = acre-feet per year
Notes
"eWRIMS" = Electronic Water Rights Information Management System
(a) Those rightsholders identified upstream of Cloverdale's diversions per eWRIMS, located primarily in the Upper Watershed.
(b) Those rightsholders identified downstream of Cloverdale's divesions per eWRIMS, located primarily in the Lower Watershed.
(c) Based on average historic use reported to the SWRCB, this does not necessarily match the full extent, entitlement, or "face value" of these water rights.
Location Status Rightsholders
Downstream (b)
Upstream (a)
Table 12
Aggregated Russian River Watershed Water Rights Compared to Cloverdale Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Estimated Total (AFY) (c)
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8 COMPARISON OF SUPPLY AND DEMAND
Pursuant to CWC §10910(c)(3) and CGC §66473.7(a)(2), this WSA/WSV includes a summary of the availability of water supplies over a historical record of 20 years (Table 6), an estimate of the projected water supplies available to the City under normal, single-dry, and multiple-dry years (Tables 7, 8, and 9), and a discussion of whether those supplies will meet the projected demand associated with the Proposed Project, in addition to the water system’s existing and planned future uses. This assessment is parallel to the multiple-dry year supply reliability analysis required for UWMPs under CWC §10635. In 2018, CWC §10635 was revised to require UWMPs to extend this analysis to consider “a drought lasting five consecutive water years (WYs).” Although CWC §10910(c)(3) has not yet been updated to require this for WSA/WSVs, a five-year drought scenario is also evaluated herein for the purposes of a conservative analysis.
As demonstrated in this WSA/WSV, the City’s existing entitlements (Section 6.2.1) and infrastructure upgrades (Section 6.2.2) are expected to provide sufficient supply to meet all future demands including those associated with the Proposed Project under normal year conditions through 204548. The On-Site water rights, to the extent they are utilized, also offer additional non-potable supplies to ensure compliance with regulatory conditions.
While the City’s senior water rights significantly reduce the likelihood of curtailment, the 2021 drought demonstrated that temporary supply restrictions may still occur during extreme conditions and shortfalls of up to 11% are possible. Even in such cases, however, minimum health and safety standards are guaranteed, and the City has successfully petitioned for enhanced allocations, maintaining essential service levels. Further, because available supplies scale with population under the curtailment scenario, the Proposed Project will not impact any of the City’s existing residents (see Section 7.3.3 for details).
Water Shortage Contingency Planning
While supply shortfalls for Cloverdale are not projected for the Proposed Project under normal conditions, shortfalls identified in dry year conditions and shortfalls resulting from any cause (e.g., droughts, curtailments, impacted distribution system infrastructure, regulatory-imposed shortage restrictions, etc.) that could occur in the future would be managed through the implementation of the City’s latest WSCP. The overall reduction goals in the WSCP are established for six drought stages ranging from 10% to greater than 50% shortfalls. As a customer within the City the Proposed Project would be obligated to comply with the demand reduction efforts imposed by the City through implementation of the WSCP in any future water shortage conditions.
In 2015, then-Governor Brown issued the fourth in a series of EOs regarding actions necessary to address California’s severe drought conditions between 2014 and 2017. With implementation of its WSCP during the historic five-year 2014 through 2017 drought, the City achieved a demand reduction of about 8.8% (2017 water demand compared to 2014 water demand; SWRCB, 2025). 48 Specifically, those essential demands in extended drought conditions where Cloverdale’s right may be curtailed.
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From 2014 through 2016, the City diverted the smallest volume of water from the Russian River in recent history (Cloverdale, 2021)49 .
Cloverdale similarly enacted certain mandatory rationing and emergency conditions during the 2021 curtailment orders, in response to water supply limitations based on health and safety standards. Cloverdale reached a Stage 4 “Water Shortage Emergency” to meet water use reduction mandates, requiring 35% reduction in water usage by all residents and businesses, prohibitions on water waste, mandatory leak repairs within 72 hours, issuance of excessive use notifications, and the implementation of a water shortage surcharge on customer water usage charges (Cloverdale, 2025a). This included the submission of monthly water diversion reports to relevant state agencies to confirm its compliance. The City retracted to Stage 2 of its WSCP in June 2022 and implemented numerous drought response actions, aimed at a mandated 15% reduction in water usage by the state. The City’s demands decreased by 21% in 2022 compared to its 2020 demands (SWRCB, 2025). In March 2023, Governor Newsom signed EO N-5-23 easing emergency drought requirements and no longer mandating urban water suppliers to implement Stage 2 demand reduction actions. Subsequently, the City Council voted to return to Stage 1 of its WSCP on 12 April 2023, which encourages voluntary conservation and continued adherence to water efficiency best practices.
It should be noted that the City does not have reductions in water supply allocated to a specific sector pursuant to CGC §66473.7(a)(2)(C). However, as a customer within the City, the Proposed Project would be obligated to comply with the demand reduction efforts imposed by the City through implementation of the WSCP in any future water shortage conditions – see Appendix F for excerpts from the WSCP showing the stages and actions Cloverdale would take under certain conditions. As such, the Proposed Project would contribute a proportionate share of the reduction in water demand during dry years.
Urban Water Conservation
The Conservation Legislation set new requirements for urban water agencies to continue to increase water efficiency beyond the former 2020 water use targets developed under the SB X7-750. As of 2024, certain water suppliers, including Cloverdale, are required to report their compliance with an established UWUO, to be enforced by the SWRCB51 through various demand factor estimates(discussed in more detail below). In addition, the Conservation Legislation added new requirements related to drought planning and WSCPs, including requirements for agencies to: (1) conduct a drought risk assessments part of their future UWMPs to assess water supply reliability (or vulnerability) for a period of drought lasting five consecutive WYs (CWC §10635(b)), and (2) conduct annual water supply and demand assessments to determine its water supply reliability for the current year and one dry year (CWC §10632(a)). These elements were incorporated into the City’s WSCP.
49 Based on data from 2020 UWMP Update, note more-recent data not available until release of Cloverdale’s anticipated 2025 UWMP Update. 50 These SB X7-7 targets were the basis for conservation reporting in the 2020 UWMP Update. 51 Through analyses performed by the California Department of Water Resources (DWR).
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UWUOs set an “efficient urban water use” for suppliers based on industry-accepted and DWR analyzed water use efficiency standards and service area characteristics. Given the City’s most recent UWUO Report submitted to DWR in 2024, their actual water use was approximately 29% below the estimated UWUO, indicating proper compliance and meeting their water use targets (DWR, 2024). The Proposed Project is not expected to adversely impact the City’s ability to meet these UWUO requirements, given the efficient water demands planned and current compliance level.
Planned Supplemental Supplies
The Proposed Project is being designed with a strong emphasis on long-term water conservation and efficiency. As part of this commitment, the Project Proponent intends to evaluate the feasibility of integrating non-potable water supply systems to offset its landscape irrigation and other discretionary water uses.
Potential non-potable sources under consideration include:
• On-Site water rights (see Section 6.2.1) that may allow for limited uses of additional Russian River underflows, junior in priority to the City’s water rights and subject to certain SWRCB reviews and approvals;
• Graywater reuse systems, capturing water from showers, sinks, and laundry for landscape irrigation or subsurface distribution;
• Recycled water, which the City is exploring as an alternative source of water supply52; and • Stormwater capture and reuse, designed to collect, treat, and store runoff for supplemental irrigation, dust control, fire protection, etc.
Although the final design and extent of these systems have not yet been determined, the Proposed Project’s planning team is actively assessing technical feasibility, regulatory compliance and cost-effectiveness to identify opportunities for implementation. Incorporating non-potable supply infrastructure will help ensure that the Proposed Project aligns with state conservation mandates (SB 606, AB 1668) and MWELO requirements while reducing reliance on the City’s potable water supplies.
Because these measures are still under evaluation and have not been finalized, the potential contributions of the On-Site water rights, as well as from recycled water, greywater reuse or stormwater capture systems, are not included in the demand estimates or water supply analysis in this WSA/WSV. However, the Proposed Project’s intent to pursue these alternative sources, 52 The Project Proponent has expressed interest in exploring recycled water for non-potable landscape irrigation uses by the Proposed Project. Because specific recycled water sources, conveyance infrastructure, and service arrangements have not yet been developed, this WSA/WSV acknowledges recycled water as a future possibility but does not quantify corresponding demand offsets. If pursued, recycled water could be provided by a future City owned and operated system. Alternatively (or in addition), the Proposed Project may collect certain greywater generated from the residential, resort, and other on-Site developments. The resulting non-potable supply(ies) would be delivered to designated irrigation areas through a dedicated distribution system with clearly defined outflow points.
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particularly for large, irrigated areas such as the Great Lawn and other landscaped open spaces, demonstrating a clear commitment to sustainable and efficient water management. These strategies are consistent with statewide water use efficiency standards and align with the City’s long-term resource management and conservation goals.
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Should such systems ultimately be implemented, they would reduce potable water demand and enhance the Project’s overall supply reliability and resilience during dry periods. Table 11 presents a revised normal year projection illustrating the potential effects of incorporating these systems on total available supplies and Proposed Project demands.
Supply-Demand Comparison
Consistent with the 2020 UWMP and the quantitative analyses presented herein, the City is expected to maintain sufficient and reliable supplies to meet projected and expanded Service Area demands – including those associated with the Proposed Project under normal, single-dry, and multiple-dry year conditions32. This conclusion reflects:
1. The continued reliability and seniority of the City’s Russian River underflow right;
2. Demonstrated performance of the WSCP during recent droughts; and
3. The City’s active compliance with state UWUO standards.
Additional analyses (Section 7) indicate that reliability is expected to persist even under future droughts, curtailments, or following the decommissioning of the PVP. To further strengthen resilience, the City is advancing a Water Resiliency Program that includes new supply wells, recycled water, and storage projects, leak-reduction efforts, and potential new water sources (West Yost, 2025; Appendix D).
The Project Proponent also plans to evaluate on-site non-potable options, such as use of existing water rights or recycled water/greywater/stormwater systems, to offset landscape irrigation demands, further supporting system reliability and sustainability.
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2025 2030 2035 2040 2045
910 910 910 910 910
477 547 571 591 606
Russian River Underflows (b) 477 547 571 591 606
Non-Potable Water
City Demand Inclusive of Proposed Project - Including Irrigated Landscaping City 2020 UWMP Water Demand (d) 532 565 570 583 600
Proposed Project Demand (e) 0 46 69 76 76
Total Demand (Including Irrigated Landscaping) 532 611 639 659 676 Supply Shortfall (% demand) (f) 10% 10% 11% 10% 10%
City Demand Inclusive of Proposed Project - Not Including Irrigated Landscaping City 2020 UWMP Water Demand (d) 532 565 570 583 600
Proposed Project Demand (without Landscaping) (e) 0 20 42 49 49 Total Demand (Not Including Irrigated Landscaping) 532 585 612 632 649 Supply Shortfall (% demand) (f) 10% 6% 7% 6% 7%
"SWRCB" = State Water Resources Control Board
"UWMP" = Urban Water Management Plan
"WSA" = Water Supply Assessment
"WSV" = Water Supply Verification
Table 13
Projected Single Dry Year Supplemental Water Supply and Demand Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Water Supply and Demand
(c)
Projected Single Dry Year Water Supply and Demand
(MGY)
Surface Water Entitlements (a)
Single Dry Year Supply
Abbreviations:
"AB" = Assembly Bill
"City" = City of Cloverdale
"gpcd" = gallons per capita per day
"MGY" = million gallons per year
"Project Proponent" = Esmeralda Land Company, LP
"Proposed Project" = Esmeralda Land Company Mixed-Use
Development Project
0 100
200
300
400
500
600
700
800
900
1,000
Projected Water Supply and Demand (MG)
2025 2030 2035 2040 2045
Projected Single Dry Year Supplemental Water Supply and Proposed Project Demand
Total Demand (Not Including Irrigated Landscaping)
Total Demand (Including Irrigated Landscaping)
Surface Water Entitlements (a)
Single Dry Year Supply
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Table 13
Projected Single Dry Year Supplemental Water Supply and Demand Esmeralda Land Company Mixed-Use Development Project, City of Cloverdale, California Notes:
(a)
(b)
(c)
(d)
(e)
(f)
References:
1. Water supply available to the City during single dry years is based on the dry year supply projections presented in Reference 1. Although the City has pre-1914 water rights on the Russian River with an entitlement of up to 910 MGY, the UWMP conservatively assumes supply shortfalls that range from 10% to 11% in 2025-2040 in single dry years. In this context, shortfalls refer to the difference between dry year impacted water supplies and corresponding demands, not the percentage reduction from average supplies as shown in Table 7-3 of the 2020 UWMP. This 10-11% supplydemand shortfall indicates that while the City can use its senior water right, it would trigger its WSCP and implement demand management measures and conservation efforts to reduce demands, thus decreasing the necessary supply.
The Project Proponent intends to evaluate the feasibility of securing non-potable water supplies—such as use of the on-site water rights or recycled water and stormwater capture—to offset the Proposed Project’s landscape irrigation demands and to comply with regulatory requirements (e.g., AB 1572). While these non-potable supplies are not directly evaluated in this WSA/WSV for landscape irrigation uses, they are being assessed as potential sources to meet irrigation demands.
The City holds pre-1914 rights to divert water from Russian River Underflows, exercised via use of shallow wells located adjacent to the Russian River. This table reflects the full claimed entitlement of these rights - see SWRCB Statement ID S014237 for details. The City holds additional rights to divert from Big Sulphur Creek not included in this table.
Cloverdale, 2021. 2020 Urban Water Management Plan for the City of Cloverdale, prepared by Woodard & Curran, dated May 2021.
The City’s 2020 UWMP did not provide estimates for projected water demands in 2045. For purposes of this WSA/WSV, 2045 demand values were estimated by assuming an average growth rate in population from 2025 to 2040 to estimate a 2045 population value of 14,061. A gpcd of 117 was applied to the 2045 population projection to estimate an annual projected water use of 600 MGY, consistent with the methodology followed in the 2020 UWMP.
The City's 2020 UWMP demands are inclusive of the Baumgardner Ranch Development Project, an approximately 300 housing unit development over 20 acres, which is incorporated into the City's latest growth and water demand projections per Reference 1.
As discussed in Section 5 of this WSA/WSV, the Proposed Project demands are not included within the 2020 UWMP and are, therefore, considered additive to City demands.
In single dry year scenarios, shortfalls are projected at 10-11% if the Proposed Project utilizes potable sources for its landscaping demands, and 7-10% if the Proposed Project utilizes non-potable sources for its landscaping demands.
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9 CONCLUSIONS
In accordance with California Water Code (CWC) §10910(c)(4) and California Government Code (CGC) §66473.7(a), this Water Supply Assessment (WSA) and Water Supply Verification (WSV) for the Proposed Project concludes that the City of Cloverdale (City) possesses sufficient and reliable water supplies to serve existing customers and the Proposed Project through the 2045 required WSA/WSV planning horizon, under a range of hydrologic conditions evaluated.
Key WSA/WSV conclusions include:
1. Projected Demand (Section 4): a conservative projected water demand of the Proposed Project is 76 million gallons per year (MGY) at full buildout by 2040 including landscape irrigation uses – for reference Cloverdale’s entire 2024 demand was 363 MGY (see Table 4).
This estimate is based on standard land use factors consistent with Cloverdale’s latest 2020 Urban Water Management Plan (UWMP) and recent City water use trends.
2. Project Efficiency (Section 4): the Proposed Project’s commitment to water-efficiency design and use of non-potable supplies towards outdoor demandsis expected to reduce its demands and align with statewide conservation goals.
3. Sufficient Supply (Section 6): the City’s senior Russian River underflow water right and associated municipal well system – including planned and implemented upgrades - provide a stable and reliable supply under the vast majority of conditions.
4. Dry-Year Management (Section 6): during single or multiple dry years (and droughts), any temporary shortfalls would be addressed through the City’s Water Shortage Contingency Plan (WSCP) consistent with the conservative planning assumptions used in its 2020 UWMP.
5. Resiliency and Adaptation (Section 7): the City’s Water Resiliency Program (West Yost, 2025), ongoing Urban Water Use Objective (UWUO) standards compliance, and planned infrastructure projects (e.g., additional wells, storage, and recycled-water systems) will further enhance long-term reliability – even given potential risk factors such as regulatory curtailments, Potter Valley Project decommissioning, and future hydrologic uncertainties (see Appendix E).
Accordingly, based on the analyses and assumptions contained in this WSA/WSV and the City’s 2020 UWMP, Cloverdale is expected to have sufficient and reliable water supplies to meet projected demands – including those associated with the Proposed Project – through 2045 under normal and reasonably foreseeable dry-year conditions.
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10 REFERENCES
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United States Geological Survey. (n.d.). USGS station 11463000: Mean daily flow rate. National Water Information System, accessed 9 October 2025,
(https://waterdata.usgs.gov/monitoring-location/USGS-11463000/).
U.S. Census Bureau, 2023. U.S. Census Bureau QuickFacts: Cloverdale City, California (2019–2023 ACS 5-Year Estimates), accessed 20 June 2025,
(https://www.census.gov/quickfacts/fact/table/cloverdalecitycalifornia/HSG651223).
Valley of the Moon Water District (VOMWD), 2021. 2020 Urban Water Management Plan, Valley of the Moon Water District, dated June 2021.
West Yost, 2025. Water Resiliency Program Assessment and Initial Project List, dated July 2025.
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APPENDIX A
Referenced CGC, CWC, and CBPC Provisions
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2. GENERAL REQUIREMENTS FOR THE PREPARATION OF A WSA AND WSV
2.1 Applicability of CWC, CGC, and State Guidelines to Proposed Project CWC § 10910
(a) Any city or county that determines that a project, as defined in Section 10912, is subject to the California Environmental Quality Act (Division 13 (commencing with Section 21000) of the Public Resources Code) under Section 21080 of the Public Resources Code shall comply with this part. CWC § 10912
For the purposes of this part, the following terms have the following meanings:
(a) "Project" means any of the following:
(1) A proposed residential development of more than 500 dwelling units. (2) A proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space.
(3) A proposed commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space.
(4) A proposed hotel or motel, or both, having more than 500 rooms. (5) A proposed industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area. (6) A mixed-use project that includes one or more of the projects specified in this subdivision. (7) A project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500 dwelling unit project.
(b) If a public water system has fewer than 5,000 service connections, then “project” means any proposed residential, business, commercial, hotel or motel, or industrial development that would account for an increase of 10 percent or more in the number of the public water system’s existing service connections, or a mixed-use project that would demand an amount of water equivalent to, or greater than, the amount of water required by residential development that would represent an increase of 10 percent or more in the number of the public water system’s existing service connections.
CGC § 66473.7
(a) For the purposes of this section, the following definitions apply:
(1) "Subdivision" means a proposed residential development of more than 500 dwelling units, except that for a public water system that has fewer than 5,000 service connections, "subdivision" means any proposed residential development that would account for an increase of 10 percent or more in the number of the public water system's existing service connections.
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2.2 Responsibility for Preparation of the WSA and WSV
CGC § 66473.7
(i) This section shall not apply to any residential project proposed for a site that is within an urbanized area and has been previously developed for urban uses, or where the immediate contiguous properties surrounding the residential project site are, or previously have been, developed for urban uses, or housing projects that are exclusively for very low and low-income households.
CBPC § 11010
(b)(6) A true statement of the provisions, if any, that have been made for public utilities in the proposed Subdivision, including water, electricity, gas, telephone, and sewerage facilities. For subdivided lands that were subject to the imposition of a condition pursuant to subdivision (b) of Section 66473.7 of the Government Code, the true statement of the provisions made for water shall be satisfied by submitting a copy of the written verification of the available water supply obtained pursuant to Section 66473.7 of the Government Code. CWC § 10910
(b) The city or county, at the time that it determines whether an environmental impact report, a negative declaration, or a mitigated negative declaration is required for any project subject to the California Environmental Quality Act pursuant to Section 21080.1 of the Public Resources Code, shall identify any water system that is, or may become as a result of supplying water to the project identified pursuant to this subdivision, a public water system, as defined in Section 10912, that may supply water for the project. If the city or county is not able to identify any public water system that may supply water for the project, the city or county shall prepare the water assessment required by this part after consulting with any entity serving domestic water supplies whose service area includes the project site, the local agency formation commission, and any public water system adjacent to the project site.
CGC § 66473.7
(a)(3) "Public water system" means the water supplier that is, or may become as a result of servicing the subdivision included in a tentative map pursuant to subdivision (b), a public water system, as defined in Section 10912 of the Water Code, that may supply water for a subdivision. (b)(1) The legislative body of a city or county or the advisory agency, to the extent that it is authorized by local ordinance to approve, conditionally approve, or disapprove the tentative map, shall include as a condition in any tentative map that includes a subdivision a requirement that a sufficient water supply shall be available. Proof of the availability of a sufficient water supply shall be requested by the subdivision applicant or local agency, at the discretion of the local agency, and shall be based on written verification from the applicable public water system within 90 days of a request.
(2) If the public water system fails to deliver the written verification as required by this section, the local agency or any other interested party may seek a writ of mandamus to compel the public water system to comply. (4) If the written verification is not provided by the public water system, notwithstanding the local agency or other interested party securing a writ of mandamus to compel compliance with this section, then the local agency may make a finding that sufficient water supplies are, or will be, available prior to completion of the subdivision that will satisfy the requirements of this section. This finding shall be made on the record and supported by substantial evidence.
(l) Nothing in this section shall preclude the legislative body of a city or county, or the designated advisory agency, at the request of the applicant, from making the determinations required in this section earlier than required pursuant to subdivision (b).
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2.3 Components of a WSA and WSV
CWC § 10910
(c)(4) If the city or county is required to comply with this part pursuant to subdivision (b), the water supply assessment for the project shall include a discussion with regard to whether the total projected water supplies, determined to be available by the city or county for the project during normal, single dry, and multiple dry water years during a 20-year projection, will meet the projected water demand associated with the proposed project, in addition to existing and planned future uses, including agricultural and manufacturing uses. CWC § 10911
(b) The city or county shall include the water supply assessment provided pursuant to Section 10910, and any information provided pursuant to subdivision (a), in any environmental document prepared for the project pursuant to Division 13 (commencing with Section 21000) of the Public Resources Code. (c) The city or county may include in any environmental document an evaluation of any information included in that environmental document provided pursuant to subdivision (b). The city or county shall determine, based on the entire record, whether projected water supplies will be sufficient to satisfy the demands of the project, in addition to existing and planned future uses. If the city or county determines that water supplies will not be sufficient, the city or county shall include that determination in its findings for the project. CGC § 66473.7
(a)(2) "Sufficient water supply" means the total water supplies available during normal, single-dry, and multipledry years within a 20-year projection that will meet the projected demand associated with the proposed subdivision, in addition to existing and planned future uses, including, but not limited to, agricultural and industrial uses. In determining "sufficient water supply," all of the following factors shall be considered:
(A) The availability of water supplies over a historical record of at least 20 years. (B) The applicability of an urban water shortage contingency analysis prepared pursuant to Section 10632 of the Water Code that includes actions to be undertaken by the public water system in response to water supply shortages.
(C) The reduction in water supply allocated to a specific water use sector pursuant to a resolution or ordinance adopted, or a contract entered into, by the public water system, as long as that resolution, ordinance, or contract does not conflict with Section 354 of the Water Code. (D) The amount of water that the water supplier can reasonably rely on receiving from other water supply projects, such as conjunctive use, reclaimed water, water conservation, and water transfer, including programs identified under federal, state, and local water initiatives such as CALFED and Colorado River tentative agreements, to the extent that these water supplies meet the criteria of subdivision (d).
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5. CITY OF CLOVERDALE WATER DEMAND
6. CITY OF CLOVERDALE SERVICE AREA WATER SUPPLY
CWC § 10910 (c)
(c)(1) The city or county, at the time it makes the determination required under Section 21080.1 of the Public Resources Code, shall request each public water system identified pursuant to subdivision (b) to determine whether the projected water demand associated with a proposed project was included as part of the most recently adopted urban water management plan adopted pursuant to Part 2.6 (commencing with Section 10610).
(2) If the projected water demand associated with the proposed project was accounted for in the most recently adopted urban water management plan, the public water system may incorporate the requested information from the urban water management plan in preparing the elements of the assessment required to comply with subdivisions (d), (e), (f), and (g).
(3) If the projected water demand associated with the proposed project was not accounted for in the most recently adopted urban water management plan, or the public water system has no urban water management plan, the water supply assessment for the project shall include a discussion with regard to whether the public water system's total projected water supplies available during normal, single dry, and multiple dry water years during a 20-year projection will meet the projected water demand associated with the proposed project, in addition to the public water system's existing and planned future uses, including agricultural and manufacturing uses.
CGC § 66473.7
(c) The applicable public water system's written verification of its ability or inability to provide a sufficient water supply that will meet the projected demand associated with the proposed subdivision as required by subdivision (b) shall be supported by substantial evidence. The substantial evidence may include, but is not limited to, any of the following:
(1) The public water system's most recently adopted urban water management plan adopted pursuant to Part
2.6 (commencing with Section 10610) of Division 6 of the Water Code. (2) A water supply assessment that was completed pursuant to Part 2.10 (commencing with Section 10910) of Division 6 of the Water Code.
(3) A groundwater sustainability plan adopted or alternative approved pursuant to Part 2.74 (commencing with Section 10720) of Division 6 of the Water Code.
(4) Other information relating to the sufficiency of the water supply that contains analytical information that is substantially similar to the assessment required by Section 10635 of the Water Code.
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6.1 Identification of Water Supply Rights
CWC § 10910
(d)(1) The assessment required by this section shall include an identification of any existing water supply entitlements, water rights, or water service contracts relevant to the identified water supply for the proposed project, and a description of the quantities of water received in prior years by the public water system, or the city or county if either is required to comply with this part pursuant to subdivision (b), under the existing water supply entitlements, water rights, or water service contracts. CGC § 66473.7
(d) When the written verification pursuant to subdivision (b) relies on projected water supplies that are not currently available to the public water system, to provide a sufficient water supply to the subdivision, the written verification as to those projected water supplies shall be based on all of the following elements, to the extent each is applicable:
(1) Written contracts or other proof of valid rights to the identified water supply that identify the terms and conditions under which the water will be available to serve the proposed subdivision. (2) Copies of a capital outlay program for financing the delivery of a sufficient water supply that has been adopted by the applicable governing body.
(3) Securing of applicable federal, state, and local permits for construction of necessary infrastructure associated with supplying a sufficient water supply.
(4) Any necessary regulatory approvals that are required in order to be able to convey or deliver a sufficient water supply to the subdivision.
(g) The written verification prepared under this section shall also include a description, to the extent that data is reasonably available based on published records maintained by federal and state agencies, and public records of local agencies, of the reasonably foreseeable impacts of the proposed subdivision on the availability of water resources for agricultural and industrial uses within the public water system's service area that are not currently receiving water from the public water system but are utilizing the same sources of water. To the extent that those reasonably foreseeable impacts have previously been evaluated in a document prepared pursuant to the California Environmental Quality Act (Division 13 (commencing with Section 21000) of the Public Resources Code) or the National Environmental Policy Act (Public Law 91-190) for the proposed subdivision, the public water system may utilize that information in preparing the written verification.
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7. COMPARISON OF SUPPLY AND DEMAND
CWC § 10910
(c)(3) If the projected water demand associated with the proposed project was not accounted for in the most recently adopted urban water management plan, or the public water system has no urban water management plan, the water supply assessment for the project shall include a discussion with regard to whether the public water system's total projected water supplies available during normal, single dry, and multiple dry water years during a 20-year projection will meet the projected water demand associated with the proposed project, in addition to the public water system's existing and planned future uses, including agricultural and manufacturing uses.
CGC § 66473.7
(a)(2) "Sufficient water supply" means the total water supplies available during normal, single-dry, and multipledry years within a 20-year projection that will meet the projected demand associated with the proposed subdivision, in addition to existing and planned future uses, including, but not limited to, agricultural and industrial uses. In determining "sufficient water supply," all of the following factors shall be considered:
(A) The availability of water supplies over a historical record of at least 20 years. (B) The applicability of an urban water shortage contingency analysis prepared pursuant to Section 10632 of the Water Code that includes actions to be undertaken by the public water system in response to water supply shortages.
(C) The reduction in water supply allocated to a specific water use sector pursuant to a resolution or ordinance adopted, or a contract entered into, by the public water system, as long as that resolution, ordinance, or contract does not conflict with Section 354 of the Water Code.
(D) The amount of water that the water supplier can reasonably rely on receiving from other water supply projects, such as conjunctive use, reclaimed water, water conservation, and water transfer, including programs identified under federal, state, and local water initiatives such as CALFED and Colorado River tentative agreements, to the extent that these water supplies meet the criteria of subdivision (d). (a)(3) If the written verification provided by the applicable public water system indicates that the public water system is unable to provide a sufficient water supply that will meet the projected demand associated with the proposed subdivision, then the local agency may make a finding, after consideration of the written verification by the applicable public water system, that additional water supplies not accounted for by the public water system are, or will be, available prior to completion of the subdivision that will satisfy the requirements of this section. This finding shall be made on the record and supported by substantial evidence. (e) If there is no public water system, the local agency shall make a written finding of sufficient water supply based on the evidentiary requirements of subdivisions (c) and (d) and identify the mechanism for providing water to the subdivision.
(f) In making any findings or determinations under this section, a local agency, or designated advisory agency, may work in conjunction with the project applicant and the public water system to secure water supplies sufficient to satisfy the demands of the proposed subdivision. If the local agency secures water supplies pursuant to this subdivision, which supplies are acceptable to and approved by the governing body of the public water system as suitable for delivery to customers, it shall work in conjunction with the public water system to implement a plan to deliver that water supply to satisfy the long-term demands of the proposed subdivision.
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CGC § 66473.7
(j) The determinations made pursuant to this section shall be consistent with the obligation of a public water system to grant a priority for the provision of available and future water resources or services to proposed housing developments that help meet the city’s or county’s share of the regional housing needs for lower income households, pursuant to Section 65589.7.
(o) Any action challenging the sufficiency of the public water system’s written verification of a sufficient water supply shall be governed by Section 66499.37.
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APPENDIX B
Esmeralda Land Company Mixed-Use
Development Project Phasing Plan
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APPENDIX C
Comparison of Proposed Project GPCD to UWMP Baseline GPCD November 2025 Page 88 of 112 EKI C40214.01
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Water Use By Customer Sector (MGY)
Single Family 0 2.5 9 9 9
Multi-Family 0 0 9 16 16
Commercial 0 12.5 17 17 17
Industrial 0 0 0.00 0 0
Landscaping 0 26 27 27 27
0 41 62 68 68
GPCD Estimation
Assumed Persons Per Household (b) 0 2.52 2.52 2.52 2.52 Total Proposed Project Residential Units 0 47 621 621 621 Estimated Peak Residential Population 0 118 1565 1525 1565 0 955 108 122 119
Abbreviations:
"City" = City of Cloverdale
"GPCD" = gallons per capita per day
"MGY" = million gallons per year
"Proposed Project" = Esmeralda Land
Company Mixed-Use Development Project
"UWMP" = Urban Water Management Plan
"CII" = Commercial, Industrial, & Institutional
Notes:
(a) Does not include distribution system losses.
(b)
(c)
Reference:
1. 2.
The average persons per household for the City is assumed to be 2.52 based on the U.S. Census Bureau per Reference 1.
Cloverdale, 2021. 2020 Urban Water Management Plan for the City of Cloverdale, prepared by Woodard & Curran, dated May 2021.
U.S. Census Bureau, 2023. U.S. Census Bureau QuickFacts: Cloverdale City, California (2019–2023 ACS 5-Year Estimates), accessed 20 June 2025,
(https://www.census.gov/quickfacts/fact/table/cloverdalecitycalifornia/HSG651223).
The high GPCD in 2030 is due to high landscaping water demand and low residential and CII use and population.
This GPCD is not representative of the Proposed Project at full buildout.
Appendix C
Comparison of Proposed Project GPCD to UWMP Baseline GPCD Proposed Project 2025 2030 2035 2045
Total Water Use (MGY) (a)
Total GPCD (c)
2040
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APPENDIX D
City’s Additional Water Supply Projects Identified in Water Resiliency Program November 2025 Page 90 of 112 EKI C40214.01
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Water Resiliency Program Assessment and Initial Project List Project Name Description
Included
in CIP CIP # Status Timeline Estimated Cost* Notes
Supply Wells
Source Capacity Study Hydrogeologic study - Eastside of river and north of Well #13 . Y WA-061 Not started Near Term Low City-wide study as an option New Domestic Supply Well Study Desk study to find the best location to install a new well away from the surface water. Y WA-062A Not started Near Term Low WTP Wells Drill a new well and second redundant well on City property on the east side of the Russian River. Install transmission main from new well to WTP (includes river crossing). Y WA-062 Not started Long Term High Park Irrigation Wells Permitting and installation of non-potable irrigation wells. N Not started Long Term High City parks are within jurisdictional boundary of Russian River
Obtaining Water Rightsto Lake Mendocino Work with Sonoma Water on an agreement to purchase Lake Mendocino water. N In progress Near Term Medium Well Replacement #7 The project will replace Well #7, which is in poor condition with cracks in its casing. Y WA-063 In construction Near Term Medium Well Rehabilitation #8 The project will replace Well #8, which experiences air entrainment. Y WA-086 In construction Near Term Medium Recycled Water
Recycled Water - Feasibility Study Evaluate feasibility of advanced water treatment and distribution. N In progress Near Term Medium Grant funded Water Treatment Plant Upgrade to Advanced
Water Treatment
Upgrade wastewater treatment plant to provide advanced treated water. Exceed tertiary treatmentrequirements, and provide reclaimed water to users.
Y SA-031 Not started Long Term Very High
Recycled Water - Purple Pipe Installations Install recycled water distribution system(s). N Not started Long Term High Depends on user/customer locations Above Ground Storage Tanks
Cherry Creek (Southcrest) Reservoir Rehabilitation Replace Cherry Creek Reservoir with two new 250,000-gallon seismically compliant tanks, increasing waterstorage capacity by 300,000 gallons. Y WA-066 In design Near Term High Ritter Reservoirs Replace Ritter Reservoir Tank #1 with a 500,000-gallon welded steel tank. Install Cathodic Protection on tank.- Re-line or replace Ritter Reservoir Tank #2.
Y WA-069 Not started Long Term High
Reservoir Siting Study Conduct reservoir siting study for Main Water Zone (Zone 1). Y WA-070 Not started Near Term Low Potable Distribution System
Water Leak Detection and Pipe Repairs Asset management of potable watersystem. N Not started Near Term High Variouslocationsin City not identified in CIP Water Main Replacement Identify and replace undersized and/or older transit water mains at N Cloverdale Blvd, Cherry Creek, and Healdsburg Avenue.
Y WA-067 Not started Near Term High
Water Master Plan Develop a Water Master Plan to evaluate hydraulics and resilience of the system (i.e. fire, alternate main reservoirsite, and system capacity needs. Y WA-064 To begin in July 2025 Near Term Medium SCADA Expansion Integrate waterfacilitiesinto supervisory control and data acquisition (SCADA)system.
Expand SCADA system to City's infrastructure at 7 remote sites.
Y WA-065 In design (30%) Near Term Medium To increase watersystem efficiency Foothill Pump Station Rehabilitation (Del Webb) Replace and upsize Foothill Pump Station pumps (3 pumps, 75 HP each) to increase future capactiy for growth. Y WA-071 Not started Long Term High Part of "Foothill Pump Station Rehabilitation
and Del Webb Reservoir Coating" project in
CIP.
Vista View Pump Station Rehabilitation Redesign and reconstruction of the abandoned Vista View Pump Station for emergency backup including new backup generator and transformer. Y WA-072 Not started Long Term Medium School Street Pump Station Rehabilitation
Reconstruct the School Street Pump Station including adding a transformer, moving pump station to above ground location, and adding a transformer and transfer switch to improve maintenance efficiency.
Y WA-073 Not started Near Term Medium
Meter Radio Read Upgrade Replace and upgrade approximately over 3,400 water meters to meters with radio read capability. Y WA-074 Complete Complete High
Number of meters replaced increased from
1,700 (as listed in CIP), to over 3,400. Grant
funded.
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APPENDIX E
Review of Cloverdale Water Supply Access Considerations November 2025 Page 92 of 112 EKI C40214.01
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24 October 2025
TECHNICAL MEMORANDUM
To: Devon Zuegel, Esmeralda Land Company, LP. (Esmeralda) Michael Yarne (Esmeralda)
Pavel Petrov (Esmeralda)
From: Wade Oliver, EKI Environment and Water, Inc. (EKI) Brad Arnold, PE, BC.WRE (EKI)
Anona Dutton, PG, CHG (EKI)
Subject: Preliminary Hydrologic Analyses of Cloverdale Water Supplies along the Russian River
PURPOSE AND BACKGROUND
The purpose ofthis Technical Memorandum (Memo) isto provide a planning-level assessment of the longterm reliability of the City of Cloverdale’s (City) water supply portfolio. The assessment focuses primarily on the hydrologic factors and watershed processes that influence the City’s ability to access Russian River Underflows (Underflows) – the shallow, hydraulically connected groundwater system adjacent to and beneath the Russian River (River) – from which the City currently obtains its municipal water supply through a series of production wells located near the River.
This Memo compiles, reviews, and interprets publicly available data on streamflow, groundwater, surface water-groundwater interactions, and related hydrologic conditions within the Russian River Watershed (Watershed). The goal is to improve understanding of the natural and managed conditions that support the City’s well field operations, and to identify factors that could influence the physical availability of Underflow water under varying hydrologic and infrastructure scenarios. A specific focus of this assessment is to evaluate the extent to which the City’s existing and planned water supply facilities, along with its senior pre-1914 water right (up to 910 million gallons per year [MGY]) from the Underflows, are resilient to potential future changes in hydrologic and operational conditions.
In addition to natural climate variability (e.g., prolonged droughts, shifting precipitation patterns, and River flow timing), the analysis considers anticipated changes in the broader regional Watershed management system, including the Pacific Gas & Electric Company’s (PG&E) planned decommissioning of its Potter Valley Project (PVP). The PVP currently provides transfers water from the Eel River into the upper East Fork Russian River1
, augmenting baseflows that benefit users. The eventual cessation or modification of these PVP diversions could have measurable implications for River state, baseflow recharge, and the sustainability of Underflow supplies available to the City.
KEY FINDINGS
Based on the review of available hydrologic, geologic, and surface water data, the following key findings are noted:
1 PG&E’s PVP decommissioning effort would remove all existing Eel River to Russian River conveyance infrastructure, thereby eliminating these diversions unless an alternative system were developed.
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1. Seasonal Supply Dynamics: The period from May to October typically represents both the City’s highest water demand and the lowest flow period in the River. Despite this overlap, available data indicate that the alluvial sediments underlying the City’s well field store substantial volumes of water, serving as a buffer that allows continued pumping even during periods of reduced river flow.
2. Historic Supply Performance: Over the past 20 years, including during several historic droughts, the City’s reliance on Underflows as its sole water source has not shown evidence of conditions wherein water was physically not available to pump from the City’s well field2 .
3. Surface Water Accounting of Upstream Operations. Analysis of upstream gage records and flow data indicates that inflows from the PVP and controlled releases from Lake Mendocino contribute to summer flow augmentation in the Upper Watershed. These contributions may enhance potential recharge to the Underflows, particularly during dry years. The planned decommissioning of PVP will likely reduce this supplemental input; however, the degree of direct impact on Cloverdale’s Underflow conditions remains limited based on available information.
4. Hydrogeologic Review. The alluvial sediments underlying the City’s well field provide a natural buffer between surface flow fluctuations and subsurface water availability. Short-term changes in river flow are not expected to produce substantial or extended changes in subsurface water levels. Only prolonged reductions in river stage – typically lasting 60 to 90 days or more – would be expected to noticeably influence the Underflows, and even then, effects are likely to be moderated by the subsurface storage capacity.
5. Overall Reliability and Outlook. Cloverdale’s senior water right provides priority access to water supplies relative to most other users, offering additional reliability during periods of curtailment or drought. Combined with the buffering capacity of the local alluvium and the redundancy of its well system, these factors suggest the City is well positioned to maintain reliable water supplies under a range of future hydrologic conditions. While regional changes such as the PVP decommissioning and broader Watershed variability are important to monitor, current evidence does not indicate any immediate or direct vulnerability for the City’s Underflow-based water supply. Implementation of the City’s Water Resiliency Program (West Yost, 2025) would further be expected to mitigate such impacts if they were to occur.
CITY WATER SYSTEM AND HISTORIC USES
Available data from the City’s latest 2020 Urban Water Management Plan Update (UWMP), City-provided production records (2004-2024)3
, and supporting infrastructure documentation show that Cloverdale’s supply – sourced solely from the Underflows – has remained stable and reliable over the past two decades. 2 Under normal conditions, the City does not run all seven wells simultaneously, allowing for well rotation and preventive maintenance to extend the operational life of each facility. However, during periods of lower subsurface water elevations, which typically coincides with periods of peak seasonal demand, the effective production capacity of the wells can be reduced due to air entrainment in the intake zone. As part of its 2022 Urban and Multi-benefit Drought Relief Grant Program, the California Department of Water Resources (DWR) awarded the City a $3M grant to reduce air entrainment and improve water supply efficiency and reliability at its well field. This funding is being used to replace and upgrade two aging supply wells that are prone to air entrainment. 3 Email from Derrick Montanye, Public Works Director, City of Cloverdale, 19 June 2025 November 2025 Page 94 of 112 EKI C40214.01
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The City operates seven wells adjacent to the River that draw water from shallow alluvial sediments hydraulically connected to the River. Figure 1 illustrates monthly water production from 2004 through 2024. Monthly pumping typically ranges between 20 and 50 million gallons (MG), with higher volumes before 2014 occasionally exceeding 60 MG per month. Total annual production during this period has ranged from approximately 325 MGY4 (1,000 acre-feet per year; AFY5 ) to 570 MGY (1,570 AFY). The
gradual reduction in total annual production since 2014 is likely attributable to improved water use efficiency (WUE) measures implemented following the 2014 drought conditions and key regulatory WUE changes, rather than any limitation on physical water availability.
As shown in Figure 2, annual production from the City’s well field exhibits a consistent and predictable seasonal pattern, with pumping volumes peaking midsummer (July) when outdoor irrigation demand is greatest and declining steadily through the fall and winter months. Median monthly production typically remains below 30 MG between November and April, reflecting reduced municipal and landscape water use during this cooler, wetter season. This recurring pattern showing stable annual peaks and troughs without evidence of a long-term downward trend or operational limitation suggests that the City’s supply wells and associated Underflow conditions have been resilient over time. Even during multiple historic drought periods, production has not shown signs of sustained decline or recovery lag, indicating that both well performance and Underflow recharge conditions have been resilient under varying hydrologic conditions.
These findingsindicate that Cloverdale’s exclusive reliance on theUnderflows has not resulted in measurable stress, depletion, or performance decline over the last 20 years. Available production well and water level data show consistent well yield and stable pumping responses, demonstrating that the Underflow system continues to provide reliable recharge and sustainable pumping capacity. Collectively, the data confirm that the City’s well field has maintained sufficient capacity to meet community water demands across a broad range of hydrologic conditions, including multiple drought cycles, thereby underscoring the overall reliability of the City's existing supply system.
4 Million gallons per year (MGY).
5 Acre-feet per year (AFY) equivalent.
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Figure 1. Cloverdale Monthly Water Production Between 2004 and 2024.
Figure 2. Range of Cloverdale Water Production by Month6 .
SURFACE WATER REVIEW
Cloverdale’s water supply from the Underflows is hydraulically connected to the Russian River and depends on the broader hydrologic systems that sustain river flows. These systems include natural watershed runoff from local tributaries, imported flows from the PVP, and managed releases from Lake Mendocino. The interactions are important among these components as they directly influence recharge to the Underflows that supply the City’s wells. Understanding the dynamics of these interconnected sources is essential for evaluating the long-term reliability of the City’s water supply and for anticipating how potential future changes such as the PVP decommissioning could affect both surface water availability and subsurface water replenishment in the area.
6 Plot represents range, upper and lower quartiles, and median values for each month. Two outlier values are plotted separately. 0 50
100
150
200
250
0 10
20 30
40 50
60 70
80 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Monthly Production (acre feet)
Monthly Production (million gallons)
January February March April May June July August September October November December Monthly Production (million gallons)
0 10
20 30
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Review of flow and storage data from the California Department of Water Resources (DWR, CDEC7 Station COY) and the United States Geological Survey (USGS Stations 11463000 and 114636828 ) indicates that
Lake Mendocino and the PVP together play a measurable, though seasonally variable, role in sustaining summer flows within the River. A map of these key surface water features is shown in Figure 3, and the River flow and PVP diversion data are presented in Figure 4. During normal and wet years, these managed releases and imported supplies supplement natural inflows, while in drought years they become a more significant portion of total flow – particularly between May and October when natural runoff diminishes.
These records allow for an evaluation of how much water enters the reservoir, how much is stored, and when releases are made to support downstream uses such as municipal diversions, agricultural supply, and environmental flow requirements9
.
Analysis of 2020 to 2024 data, including the critically dry conditions of 2021 and 2022, shows that:
• Lake Mendocino releases and PVP inflows collectively contribute approximately 30–50% of River flow at Cloverdale during late spring and summer months (as shown in Figure 5 and Figure 6 for normal and drought year conditions, respectively).
• Natural watershed inflows remain the dominant driver of annual flow volumes, especially during winter and early spring (see Figure 7 and Figure 8).
• Apparent “losses” between upstream and downstream flow gages10 - typically observed during summer (see Figure 9 in Figure 10) - are consistent with recharge to the alluvial aquifer system, which supports the City’s wells. This trend of summer differences between expected flow versus measured holds across the 2020 to 2024 data as shown in Figure 11 – which depicts the cumulative seasonal shortfall in measured flows during the summer months.
These findings suggest that the River’s summer baseflows, sustained in part by managed reservoir releases and supplemental inflows from the PVP, do contribute to recharge of the shallow alluvial aquifer that supplies the City. However, this contribution functions primarily as a seasonal enhancement rather than a critical dependency. Even underthe severely dry 2021 conditions, when bothnaturalriver discharge and PVP imports were substantially reduced, estimated recharge volumes to the Underflow remained sufficient to sustain stable subsurface water levels and meet the City’s water demands (Figure 11). This indicates that the aquifer system retains substantial capacity for natural recharge and storage buffering, contributing to the overall reliability of the City’s water supply.
Available surface water and hydrologic data confirm that managed operations at Lake Mendocino and PVP inflows play an important role in sustaining baseflows that enhance recharge supporting Cloverdale’s 7 California Data Exchange Center (CDEC) public web database containing statewide hydrologic data. 8 These gages are particularly valuable because they bracket the area relevant to Cloverdale’s wells and roughly correspond to 12-digit Hydrologic Unit Code (HUC-12) boundaries, which define contributing sub-watersheds. 9 Data for irrigation and water right diversions from the State Water Resources Control Board’s (SWRCB) Electronic Water Rights Information Management System (eWRIMS) database. With these sources(particularly CDEC data) it is possible to estimate how much of the inflow to Lake Mendocino originates from the PVP and how much continues into the Watershed downstream. 10 Based on assessment of the Watershed upstream of USGS Station 11463000, approximately 688,000 acres of drainage area (derived from the sum of contributing HUC-12 sub-watersheds). Analysis of natural flows and diversions indicates Watershed inflow production rates ranging from about 0.14 to 0.26 acre-feet per acre (AF/ac) during drought years (2020–2022) and 0.9 to
1.1 AF/ac during normal years (2023–2024), reflecting contributions from effective precipitation, return flows, and other hydrologic inputs. These ratios were used to estimate “expected” flows at downstream USGS Station 11463682, accounting for upstream measured flows, intervening sub-watershed inflows, and known diversions between gages. The comparison provides a theoretical benchmark for evaluating observed downstream flows.
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Underflows – especially in dry years and summer months (see Figure 12). These managed contributions act as a seasonal buffer, helping to stabilize subsurface water levels and maintain well performance during periods of reduced precipitation. Despite this interconnection, the City’s water supply remains fundamentally resilient. The City’s pre-1914 water right provides a degree of protection from potential upstream reductions in surface-water availability, limiting direct vulnerability to upstream hydrologic or operational changes within the Watershed. While ongoing monitoring of PVP transition outcomes and Lake Mendocino operational management is warranted, current evidence indicates no immediate or significant threatto Cloverdale’s watersupply.
In parallel,theCity is proactively advancing itsWaterResiliency Program (West Yost, 2025) which is designed to strengthen long term supply reliability through infrastructure improvements, diversified source planning, and adaptive management measures that can respond to evolving watershed and regulatory conditions.
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Figure 3. Location Map Showing Key Watershed Features
and USGS Stream Gaging Stations
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Figure 4. Russian River Flow and PVP Diversion Data
for 2020 through 2024.
Figure 5. Russian River Monthly Flow at USGS 11463000 Gage near Cloverdale for 2003 (Representing Normal Conditions).
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Figure 6. Russian River Monthly Flow at USGS 11463000 Gage near Cloverdale for 2021 (Representing Drought Conditions).
Figure 7. Russian River Flow Annual Breakdown
at USGS 11463000 near Cloverdale for 2023
(Representing Normal Conditions).
Figure 8. Russian River Flow Annual Breakdown
at USGS 11463000 near Cloverdale for 2021
(Representing Drought Conditions).
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Figure 9. Russian River Monthly Flow Actual vs. Expected at USGS 11463682 Gage Downstream of Cloverdale for 2023 (Representing Normal Conditions).
Figure 10. Russian River Monthly Flow Actual vs. Expected at USGS 11463682 Gage Downstream of Cloverdale for 2021 (Representing Drought Conditions).
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Figure 11. Accumulated Actual vs. Expected Flow Difference11 for USGS 11463682 Gage Downstream of Cloverdale.
Figure 12. Russian River May to October Period Total Flow Breakdown at USGS 11463000 Gage near Cloverdale (upstream) for 2020 to 2024.
11 Shows only accumulated total of instances where expected flow (see Footnote 9) was greater than measured flow for years 2020 through 2024, highlighting periods where these differences occur.
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GROUNDWATER AND GEOLOGIC DATA
Groundwater level data near Cloverdale were reviewed using DWR’s Sustainable Groundwater Management Act (SGMA) Data Viewer, which compiles statewide monitoring data from public and agency sources. As summarized in Table 1 and illustrated in Figure 11, five monitoring wells located within and near Cloverdale have recorded historical groundwater level measurements. These wells provide valuable insight into seasonal and long-term trends in the shallow alluvial aquifer that interacts with the Russian River Underflows supplying the City’s production wells.
According to the USGS hydrogeologic model of the Watershed12, near the City the River flows through shallow alluvial sediments about 60 to 70 feet thick. Four wells on the east side of the River, similar in depth to the City’s production wells, are constructed entirely within these sediments. One deeper well on the west side penetrates a separate, deeper aquifer system as shown in the well construction and hydrogeologic data – highlighting the distinction between the Underflows and underlying groundwater (Metzger et al., 2006).
For the shallow monitoring wells, subsurface water elevations generally mirror the regional topographic gradient - higher in the northern portion of the Cloverdale area and gradually declining towards the south, consistent with local drainage patterns and the overall slope of the Alexander Valley. Seasonal fluctuations typically range between 5 to 10 feet, reflecting natural variations in recharge and pumping demand.
Importantly, there is no evidence of a long-term decline trend in subsurface water levels over the period of record13 (Cromwell et al., 2024).
One well (ID 388079N1229994W001) exhibits short-term drawdowns during the summer months beginning in 2022, which may be attributable to localized pumping or simply measurement of pumping rather than static water levels (see Figure 12). However, because this well also has the longest and most continuous record of water level observations, it was selected as the primary reference point for evaluating the relationship between subsurface water levels and river state conditions. The analysis was done with both with and without the post-2022 water level anomalies.
Analysis of River flows and subsurface water level data indicates that the River and the shallow alluvial aquifer are hydraulically connected, but the response between them is delayed rather than instantaneous.
The riverbed sediments act like a sponge, absorbing water when the river flows are high and gradually release it back to the aquifer and wells over time. When River flow data were averaged over different time periods, the strongest correlation with subsurface water levels occurred for 60- to 90-day averages (see Figure 13 for assessment of correlation14), suggesting that subsurface water responds primarily to sustained changes in River flow rather than short term, day-to-day variations (as seen in Figure 14). This relationship holds both with and without the post-2022 water level anomalies included as shown in Figure 12 USGS, in cooperation with the SWRCB and Sonoma Water, published a study documenting development of a three-dimensional (3-D) hydrogeologic framework model of the Russian River Watershed (Cromwell et al., 2024). 13 For most wells completed into the alluvial sediments, water level elevations generally decrease from north to south consistent with the slope of the land surface. Water levels in these wells do not exhibit any long-term trends upward or downward with annual fluctuations of 5-10 feet. 14 This is because the sediments: (1) slow the flow of water relative to the river, and (2) are sufficiently thick to retain substantial water in storage within the sediments. To assess how quickly subsurface conditions respond to changes in river flows, rolling averages of river flow were developed over increasing durations between 1 and 365 days. For example, a 15-day rolling average of Russian River discharge for 25 June would reflect the average daily discharge for 11 June through 25 June.
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13. In other words, the River Underflow responds slowly and steadily to changing river conditions, with stored Underflows providing a natural buffer that helps maintain stable water levels during short dry periods or fluctuations in streamflow.
The City’s wells draw from the Underflows that are clearly under the influence of the River, but shortterm drops in River flow do not immediately reduce their availability. This is because the interaction between the River and the alluvial sediments depends on relative water levels, not just River flow. When subsurface levels are lower than the River, river water seeps downward; when they’re higher, water moves back toward the River. At low River flows (below 200 cubic feet per second; cfs), even a 50 cfs change in flow would raise the River surface elevation by only about 0.3 ft, a very small change. This means the shallow Underflows experience only minor short-term impacts from changes in the River flows.
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Figure 3. Location Map Showing Wells Near Cloverdale with Water Level Data and the USGS Cloverdale Stream Gage.
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Table 1. Wells near Cloverdale with Water Level Data
(from SGMA Data Viewer).
Figure 4. Subsurface Water Level in Well 388079N1229994W001.
Site Code Well Use Depth (feet)
388079N1229994W001 Residential 30
388016N1229966W001 Irrigation 104
387924N1229995W001 Residential 32
387910N1230099W001 Unknown 334
387816N1229871W001 Residential 20
275
280
285
290
295
300
305
1970 1980 1990 2000 2010 2020 2030
Water Level Elevation (feet above sea level)
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Figure 13. Correlation of Subsurface Water Levels to Rolling Averages of Russian River Discharge.
Figure 14. Stage Versus Russian River Discharge for USGS Gage 11463000 0 0.1
0.2 0.3
0.4 0.5
0.6 0.7
0 50 100 150 200 250 300 350 400
Correlation Coefficient
Duration of Rolling Average of Russian River Discharge (days) Correlation of Groundwater Levels to
Rolling Averages of Russian River Discharge
All Measurements Removed Likely Pumping Anomalies
1 10
100
1,000
10,000
100,000
374 376 378 380 382 384 386 388 390 392
Average Daily Discharge (cubic feet per second)
Average Daily Stage Elevation (feet above sea level)
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CONCLUSIONS
While hydrologic analysis alone cannot fully determine the City’s ability to access its water rights from the Russian River Underflows, multiple lines of evidence indicate that Cloverdale’s water supply remains stable, resilient and well protected, even under potential decommissioning of the PVP.
The conclusions from this Memo are summarized below:
Hydrologic Resilience
• The City draws water via wells in the shallow alluvial sediments next to and along the River (from the Underflows).
• The Underflows act as a subsurface reservoir, storing water that remains accessible even when River flows are low, typically in late-summer and autumn months when natural inflows are limited. • Seasonal water level fluctuations in the wells typically rise and fall by about 5 to 10 feet each year, consistent with normal recharge and pumping cycles rather than long-term decline. • The Underflows provide natural storage buffering, allowing the wells to continue producing reliably through short-term reductions in streamflow.
Connection to River Flows
• Statistical correlation between the River flows and subsurface water levels suggests the strongest relationships are found when averaged over 60 to 90 days, rather than daily or weekly intervals. • This indicates that the Underflows respond gradually to sustained hydrologic changes, reflecting longer-term trends in River stage rather than immediate fluctuations. • At lower River flows (below about 200 cfs) a 50-cfs change in flow only raises or lowers the River by about 0.3 feet, a minor shift with negligible impact on subsurface water levels. • Consequently, short-term flow variations have limited influence to or on Cloverdale’s Underflowbased water supplies, even during drier periods.
Operational Flexibility
• The City operates seven production wells tapping the Underflows and manages demand from them through a rotational pumping schedule, as described in its 2020 UWMP. • This operational redundancy allows for continued supply even if a well requires maintenance or experiences reduced performance, further enhancing system reliability.
Legal and Regulatory Protection
• Cloverdale holds one of the oldest and most senior water rights in the Watershed. • This priority provides strong protection during drought conditions or regulatory curtailment periods, ensuring the City’s continued ability to access its allocation from Underflows.
Taken together, these hydrologic, operational, and legal factors demonstrate that Cloverdale’s existing watersupply system is robust, adaptive and well-buffered against foreseeable risk. The available evidence suggests that the City’s wells and associated Underflow conditions are unlikely to experience significant adverse effects from the proposed project, the eventual PVP decommissioning or other anticipated changes in the Watershed.
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REFERENCES
Cromwell, G., Sweetkind, D. S., Langenheim, V. E., and Ely, C. P., 2024. Three-dimensional hydrogeologic framework model of the Russian River watershed, California, U.S. Geological Survey Scientific Investigations Report 2024–5083, https://doi.org/10.3133/sir20245083 Metzger, L.F., Farrar, C.D., Koczot, K.M., and Reichard, E.G., 2006. Geohydrology and waterchemistry of the Alexander Valley, Sonoma County, California: U.S. Geological Survey Scientific Investigations Report 2006-5115, https://pubs.usgs.gov/sir/2006/5115/.
West Yost, 2025. Water Resiliency Program Assessment and Initial Project List, dated July 2025.
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APPENDIX F
Water Shortage Contingency Plan - Stages, Triggers, and Response Actions November 2025 Page 111 of 112 EKI C40214.01
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0% None Encourage efficient water use by the Proposed Project's permanent residents and visitors. <1% <10% Voluntary
Restrict landscape irrigation hours (e.g., early morning and evenings); Reduce irrigation cycle; 'Swimming pools, spas, ponds, and fountains not refilled; limit washing of hard surfaces; mail direct notes and resident mailers; limit washing of automobiles and equipment; include prior stage actions. 5%
10 - 20% Mandatory Implement media campaign and web notices; Enforce existing water waste ordinances at Project Site; include prior stage actions. 10% 20 - 30% Mandatory
Limit landscape irrigation to twice per week; limit residential and non-residential uses in excess of mandatory rationing (e); no watering of landscaped areas; include prior stage actions.
22%
30 - 40% Mandatory Limit landscape irrigation to once per week; adjust water use capacitys for Project Site meters; include prior stage actions. 34% 40 - 50% Mandatory Landscape irrigation prohibited; include prior stage actions. 48% >50% Mandatory Public "Health & Safety" limitations govern; include prior stage actions. 62% Abbreviations:
"City" = City of Cloverdale"Proposed Project" = Esmeralda Land Company Mixed-Use Development Project "WSCP" = Water Shortage Contingency Plan
Notes:
(a) Consistent with Water Shortage Stages as defined in Table 1 of the City's WSCP. (b) Percent supply reduction targeted as specified by Water Shortage Stage. (c)
(d) Estimated percent reduction in water demands at full buildout based on implementation of expected actions shown. (e) Applicable to stage; based on required demand reduction applied to residential, resort community, and office and retail usess. 6 - Severe ShortageNo Shortage1 - Minor Shortage2 - Moderate Shortage3 - Significant Shortage4 - Urgent Shortage5 - Critical Shortage Water shortage actions consistent with the City WSCP; equivalent saqvings matches projected impacts on water demands specific to the Proposed Project estimated demand types at full buildout.
Appendix F
Concept Water Shortage Actions for Proposed Project
Cloverdale WSCP
Shortage Stage (a)
Percent
Reduction
Target (b)
Reduction
Type Proposed Project Expected Actions (c)
Expected Water
Demand
Reductions (d)
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Water Supply Assessment (WSA)
& Water Supply Verification (WSV)
for the
Proposed Esmeralda Project
at the Alexander Valley Resort (AVR) site
367
Site is to the east of
Highway 101, an 8 min
bike ride to downtown.
N
368
Site History
1953
Small farms & open space.
1974
An active lumber mill &
wood waste facility.
2025
Lumber mill closed in early ‘90s;
land has been remediated and
now sits fallow. 369
The site has been
approved for development for
20 years
370
Weʼve been working with City staff
on an Entitlements Package &
will seek approvals in Spring 2026
371
Public Process
June 2024 Edge Esmeralda – Open House & Month-Long Event May 22nd Project Open House – Cloverdale History Center June 2025 Edge Esmeralda – Open House & Month-Long Event June 25 th Esmeralda × Clearwater Ranch Picnic – Cloverdale Plaza July 24 th Project Open House – Cloverdale History Center July 30 th Parks, Trails, & Open Space Workshop – Veterans Hall July 31 st Keynote at 3rd Quarter Mixer – Chamber of Commerce Oct 9th Coffee with the Mayor – Cloverdale Senior Center Oct 15 th Project Open House – Veterans Hall
Nov 12th City Council & Planning Commission Joint Hearing & now this City Council Hearing on Adopting findings from the WSA/WSV 372
Approved (2018) vs Proposed (now)...
Resort
Mixed-Use
Residential
commercial
Open Space
Habitat
Habitat
Open Space
Resort
Mixed-Use
Residential
Habitat
373
374
375
376
377
378
379
380
381
382
383
384
385
386
Thank you!
387
From: D L
To: Public Comments
Subject: Questions For The Council regarding Esmeralda project Date: Thursday, December 4, 2025 3:16:52 PM
Dear Council Members,
As a new Cloverdale residents, listed below are our questions for The Council regarding the Esmeralda project.
Based upon the limited information that is available, we stand in opposition to this project. Thank you.
Don & Teresa Lawson:
• How much taxpayer money will be used to fund the development of Esmeralda? • How much money will taxpayers lose in Transient Occupancy Tax collection deferment over 10+ years to help the proposed resort become profitable?
• How much money will taxpayers pay for EIFD's?
"Whether EIFDs are beneficial or detrimental to taxpayers depends heavily on one's perspective regarding the allocation of future tax revenue and the specific oversight of individual EIFD projects. Supporters see them as a vital tool for funding needed infrastructure and housing, while critics view them as a form of tax increment financing that can be opaque and prioritize development interests over broader public needs." • How is the cost/benefit analysis being done for EIFD's for Esmerelda? Is one being done? Again, how much will the Cloverdale community pay or lose in tax revenue to help fund Esmerelda infrastructure? • What percentage of taxpayer-funded infrastructure upgrades are expected to benefit all of Cloverdale versus being exclusive to Esmeralda?
• If Cloverdale residents are partially funding, has an ROI been calculated for Esmerelda? • Has economic disruption been taken into consideration at all in the planning of Esmeralda? • Has the impact of rural gentrification been assessed? 388
From: ANGELA CORDOVA <[email protected]>
Sent: Thursday, December 4, 2025 12:45 PM
To: Todd Lands <[email protected]>; Brian Wheeler <[email protected]>; Andres Marquez <[email protected]>; Marjorie Morgenstern <[email protected]>; Mark Laskey <[email protected]>; Kevin Thompson <[email protected]>
Subject: Re: Esmeralda
Here you have Devon basing her ideology off of the Chautauqua Development Have any of you personally researched this project?
Exclusivity and Elitism: has historically been criticized for fostering an environment that appeals mainly to the white middle and upper classes, making it difficult for people of "low social standing" to participate
High Cost: Attending the summer assembly, a central component of the Chautauqua experience, requires purchasing expensive gate passes, which can cost hundreds of dollars per week, in addition to housing expenses. This cost is a major barrier to accessibility for many people
Lack of Diversity and Representation: Critics have pointed out the low representation of people of color among staff, board members, and the general population of attendees, which can lead to a lack of diverse voices and a feeling of being "devalued" or "disrespected" for certain groups
Insulation from Reality: The focus on intellectual and aesthetic self-cultivation has been seen as "insulating itself from the daily realities of great numbers of unprivileged fellow citizens," creating an "ivory tower" effect rather than true social harmony Thank you,
Angela Cordova
On 12/04/2025 11:04 AM PST ANGELA CORDOVA
389
<[email protected]> wrote:
Dear City Council
I am writing to demand accountability and transparency regarding the Esmeralda project. This development poses serious risks to our community, and the way it has been pushed forward raises significant concerns about fairness and integrity in the decision-making process.
Residents have repeatedly voiced objections, yet it appears these concerns are being ignored. Our city council was elected to represent the people—not outside developers or hidden agendas. Moving forward with this project without genuine community input is unacceptable.
I insist that the council:
1. Suspend all progress on the Esmeralda project immediately until a full, independent review is conducted.
2. Disclose all agreements and communications related to this development to ensure transparency.
3. Hold additional public forums where residents can speak and be heard before any further decisions are made.
This is not a request—it is an expectation from the community you serve.
Failure to act in the best interest of residents will not go unnoticed. We are prepared to hold our elected officials accountable.
I expect a prompt response outlining the steps you will take to address these concerns.
Thank you,
Angela Cordova
390
From: Oveata Thomas
To: Public Comments
Subject: Esmeralda Project
Date: Thursday, December 4, 2025 2:02:44 PM
Please answer:
How much taxpayer money will be used to fund the development of Esmeralda? Thank you!
Brenda Thomas
[email protected]
391
From: ANGELA CORDOVA <[email protected]>
Sent: Thursday, December 4, 2025 11:05 AM
To: Todd Lands <[email protected]>; Brian Wheeler <[email protected]>; Andres Marquez <[email protected]>; Marjorie Morgenstern <[email protected]>; Mark Laskey <[email protected]>; Kevin Thompson <[email protected]>
Subject: Esmeralda
Dear City Council
I am writing to demand accountability and transparency regarding the Esmeralda project. This development poses serious risks to our community, and the way it has been pushed forward raises significant concerns about fairness and integrity in the decision-making process.
Residents have repeatedly voiced objections, yet it appears these concerns are being ignored. Our city council was elected to represent the people—not outside developers or hidden agendas. Moving forward with this project without genuine community input is unacceptable.
I insist that the council:
1. Suspend all progress on the Esmeralda project immediately until a full, independent review is conducted.
2. Disclose all agreements and communications related to this development to ensure transparency.
3. Hold additional public forums where residents can speak and be heard before any further decisions are made.
This is not a request—it is an expectation from the community you serve. Failure to act in the best interest of residents will not go unnoticed. We are prepared to hold our elected officials accountable.
I expect a prompt response outlining the steps you will take to address these concerns.
392
Thank you,
Angela Cordova
393
From: Jennifer Sullivan <[email protected]> Sent: Wednesday, December 3, 2025 1:54 PM
To: Todd Lands <[email protected]>; Brian Wheeler <[email protected]>; Mark Laskey <[email protected]>; Andres Marquez <[email protected]>; Marjorie Morgenstern
<[email protected]>
Subject: Building Oppostion to Esmeralda
Dear City Council Members,
I am a proud Cloverdale resident and am writing to you with genuine concern about project Esmeralda. It seems to have come out of nowhere, so forgive me for a longer-than-usual email. I believe and fear the majority of Cloverdale residents are in the dark about what is being planned, how close it is to potentially being approved, and the magnitude of the impact Esmeralda will have on the heart and soul of our community.
The lack of community awareness and involvement is unfortunate and only serves to benefit Esmeralda Land Company LP and its secret investors, not the people of Cloverdale. I predict we will soon see a massive shift in community awareness and involvement to urge the members of the Cloverdale City Council not to approve Project Esmeralda.
What is in your hands is the economic future of the most wonderful community I have ever been so fortunate to live in. The threat of gentrification is real and insidious, and it doesn't only happen in cities, but rural communities, especially since the pandemic, are being gentrified.
"As it always is when discussing gentrification, the question becomes what the long-term effects the process will have on those vulnerable residents in these small and rural places who are at risk of displacement once revitalization sets in. These inhabitants, as a group, tend to lack many housing alternatives." Time Magazine - Richard E. Osjoe On the Esmeralda website, I discovered that Cloverdale is one of the few cities in the Bay Area to have reached its RHNA goals for very low- and low-income housing, but has yet to meet its moderate- and above-income housing targets. Honestly, I think it is one of the reasons why Cloverdale is so cool, distinct, and loved. It's still relatively affordable. It's one of the few Bay Area standouts, not yet entirely subjected to the overwhelming social and economic costs of gentrification. I also believe Cloverdale could meet its moderate- and above-income housing targets without Esmeralda.
Cloverdale is a vulnerable target, driven by the profit motives of Esmeralda Land Company LP and DKZ LLC, both based in Miami. I have nothing against a good investment, but when 394
investors' names are kept secret, and they have no understanding or care for the community they want to alter forever, my opinion changes.
During the November 12th City Council Meeting, Devon Zuegel said she "Loves Cloverdale," but their Edge Esmeralda event is exclusively centered in Healdsburg. A month-long living village, and they don't mention or suggest Cloverdale to share the love and some of the economic activity that will be poured into Healdsburg by the 1000+ attendees. Their website says, "This gathering is also a prototype for a permanent new town, Esmeralda. The lessons we learn will be carried forward to build this long-term vision." But there isn't a single mention of Cloverdale, even though this is where Esmeralda will be? Change is inevitable, but communities can maintain their core values as they grow, prevent gentrification, and avoid pushing out long-term residents. Cloverdale is the rarest of community gems and has succeeded so far. It is my sincerest hope that it continues to grow and not follow in Healdsburg's gentrified footsteps. I love you Healdsburg but love Cloverdale more.
Questions For The Council:
·How much taxpayer money will be used to fund the development of Esmeralda? ·How much money will taxpayers lose in Transient Occupancy Tax collection deferment over 10+ years to help the proposed resort become profitable? ·How much money will taxpayers pay for EIFD's?
"Whether EIFDs are beneficial or detrimental to taxpayers depends heavily on one's perspective regarding the allocation of future tax revenue and the specific oversight of individual EIFD projects. Supporters see them as a vital tool for funding needed infrastructure and housing, while critics view them as a form of tax increment financing that can be opaque and prioritize development interests over broader public needs." ·How is the cost/benefit analysis being done for EIFD's for Esmerelda? Is one being done? Again, how much will the Cloverdale community pay or lose in tax revenue to help fund Esmerelda infrastructure?
·What percentage of taxpayer-funded infrastructure upgrades are expected to benefit all of Cloverdale versus being exclusive to Esmeralda?
·If Cloverdale residents are partially funding, has an ROI been calculated for Esmerelda?
·Has economic disruption been taken into consideration at all in the planning of Esmeralda?
·Has the impact of rural gentrification been assessed?
Thank you kindly for your time, and sincerely,
Jennifer Louise Sullivan
395
--
Jennifer Sullivan
Writer & Parkinson's Content Creator
YouTube | Instagram | Substack
www.thewigglesproject.com
www.jenniferlouisesullivan.com
396
From: Mark Vernon
To: Public Comments
Subject: Water
Date: Monday, December 8, 2025 10:16:38 AM
Dear Town Council,
I have reviewed the Water Supply Assessment and Staff report for Agenda Item #H.1 at the Dec. 10 Council Meeting. The assessment uses many very conservative assumptions such that actual water use from the project will likely be much less than the maximum number arrived at in the assessment - and the assessment acknowledges this.
The staff report/summary contains the following sentence: "For reference, Cloverdale’s entire 2024 demand was 363 MGY."
It should be noted that Bear Republic Brewing ended brewing operations in Cloverdale in 2023. They were a very significant water user. It would be helpful to know how much water per year they were using - and therefor no longer using once they shut down operations.
Mark Vernon
26787 Dutcher Creek Rd.
397
From: Sally Evans
To: City Council
Subject: Esmeralda Development
Date: Tuesday, December 9, 2025 11:22:31 AM
Mayor and Council Members,
Please do proceed with caution regarding the Esmeralda venture. Besides the real and obvious concerns about water and infrastructure, the fact that the investor names are not being revealed is a red flag. You are astute individuals who know there is more here than an ultruistic development with a hard sell. We residents do not want simple answers from Esmeralda representatives. We need all of the facts, as this concept can change our small community irreparably, forever.
Residents have faith in your ability to weigh the advantages and disadvantages of such a development. We depend on your objective good judgment.
Thank you for your time and dedication to our vibrant small town.
Jim and Sally Evans
102 Plumeria Court
Cloverdale
Virus-free.www.avg.com
398
From: Eric Chamberlain
To: Public Comments
Subject: RE: Support for the Esmeralda Development at the Alexander Valley Resort Site Date: Tuesday, December 9, 2025 4:31:22 PM
December 9, 2025
Cloverdale City Council
124 N. Cloverdale Boulevard
Cloverdale, CA 95425
RE: Support for the Esmeralda Development at the Alexander Valley Resort Site Dear Mayor Lands, Vice Mayor Wheeler, and Councilmembers Laskey, Marquez, and Morgenstern,
I am writing to express my support for the Esmeralda development proposed for the Alexander Valley Resort site.
My husband and I moved to Cloverdale from San Francisco in 2019. We didn't end up here by accident—we chose this community deliberately. My husband has operated his law practice here for several years and serves on the board of Alexander Valley Healthcare. He is a member of the Chamber of Commerce and volunteers regularly at the Cloverdale Food Bank.
We attend Friday Night Live, the Citrus Fair, and performances at CPAC. In October, I left a job that had me commuting to Oakland three days a week so I could build my own business here in Cloverdale full-time. We've put down roots, and we're investing in this town's future.
That's why I care about this project. And that's why I've followed it closely. We watched the November 12 joint City Council and Planning Commission meeting, reviewed the materials at esmeralda.org, toured the site, and met informally with Devon Zuegel. I came away impressed by her openness and her genuine interest in hearing from residents.
I understand why some longtime residents are cautious. We've seen previous development proposals for the AVR site come and go—including one that demanded the city close our airport.[1] That history breeds skepticism, and healthy skepticism is part of what makes Cloverdale's civic culture work. But after doing my homework, I believe this project is different, and I'd like to share why.
This developer has earned trust through transparency. Unlike past proposals, Esmeralda has engaged the community early and often—through open houses, informal conversations, and public presentations. As you noted, Mayor Lands, "I have never had a developer come in and work with the city and work with me the way that they have with this project."[2] That kind of collaboration matters.
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The fiscal benefits are substantial and well-documented. The AVR site currently generates roughly $80,000 per year in property tax. According to the fiscal impact study presented to the Council, the completed development would carry an assessed value of approximately $945 million, generate $2.2 million annually in transient occupancy taxes, and create around 480 jobs. The developer would pay $77.5 million in impact fees to fund infrastructure improvements.[3] This is not the city subsidizing a project—this is a project investing in Cloverdale.
The project addresses real housing needs. Cloverdale has exceeded its RHNA targets for Very Low and Low Income housing, but we've fallen short on Moderate and Above Moderate housing.[4] This project helps fill that gap while generating tax revenue that supports services for all residents.
Water and fire safety have been thoughtfully addressed. The Water Supply Assessment conducted by EKI Environment & Water confirms that Cloverdale can meet total system demands—including this project—through 2045. Our city's senior pre-1914 water rights provide meaningful protection.[5] On fire safety, the development would have city-supplied water, paved roads, and sprinklered buildings—features that have given Fire Chief Jenkins confidence in the site.[6]
The project opens land that has been closed to the public. Sixty percent of the site would be preserved as open space, with public trails connecting to the Great Redwood Trail and SMART Pathway. A public park would be gifted to the city.[2] That's a significant community benefit from land that currently contributes little.
I'm optimistic about what Esmeralda could mean for Cloverdale. New housing options for families who want to move here. A stronger tax base to support city services. Jobs for local residents. Public amenities that benefit everyone. And a partner who has demonstrated, through actions, that they want to be part of this community—not apart from it.
My husband and I chose Cloverdale because we saw something special here. I'd like to see more people have that opportunity. I respectfully urge the Council to continue the approval process and support this project when it comes before you in early 2026. The AVR site has sat vacant long enough. This is Cloverdale's opportunity.
Thank you for your service to our community and for considering my input.
Respectfully,
Eric Chamberlain
295 S Foothill Blvd
Cloverdale, CA 95425
Sources:
[1] Press Democrat, "Alexander Valley Resort developer hasn't paid deposit to aid Cloverdale Airport closure," December 2015 https://www.pressdemocrat.com/article/news/alexandervalley-resort-developer-hasnt-paid-deposit-to-aid-cloverdale-air/ 400
[2] Esmeralda Official Website https://esmeralda.org/
[3] Press Democrat, "Rumors of tech-backed 'autonomy' stir backlash to Cloverdale Esmeralda megaproject," November 13, 2025 https://www.pressdemocrat.com/2025/11/13/are-youtrying-to-pull-a-fast-one-rumors-of-tech-backed-autonomy-stir-backlash-to-cloverdalemegaproject/ [4] Cloverdale Housing Element
https://www.cloverdale.net/DocumentCenter/View/5741/Cloverdale-Adopted--CertifiedHousing-Element-2023-09-26 [5] Esmeralda Official Website, FAQ (Water Supply Assessment by EKI Environment & Water) https://esmeralda.org/faq
[6] San Francisco Chronicle, "California Wine Country latest target for a tech utopia," October 2024 https://www.sfchronicle.com/bayarea/article/tech-utopia-wine-country-esmeralda19846531.php 401
From: Brodie Stephens
To: Public Comments; City Council; Todd Lands; Brian Wheeler; Marjorie Morgenstern; Mark Laskey; Andres Marquez; Kevin Thompson; Planning Commission; Melissa Spingler; Chad Asay; Cory Cadle; Craig Carni; William Wagy; Daniel Frankston; Jason Williams; Alex Mog at Redwood Subject: Proposed development project
Date: Tuesday, December 9, 2025 4:39:43 PM
Hi, I am a 8 year resident of Cloverdale, and would like to offer my support to any rationally planned development of the City. As I understand it the potential impacts of the Esmerelda project are upon; (a) the water system, (b) the transportation infrastructure, (c) the school system, and (d) the need for expansion of city services (such as fire, police, community healthcare, etc.)
Of those, the only material potential impact appears to be the supply of adequate water to the City in times of drought, and may be so severe as to be a "gating item" to future development.
Other communities, faced with the reality of limited water supply have enacted moratoria on development excepting only the replacement of housing stock in existence. Others have dug wells, or converted to xeriscape to save water, or otherwise met the demand with supply or conservation. I would like to know IF there is an issue, and if so, if it can be mitigated, and if it can be mitigated, at what cost.
The other burdens are common to development of a city, with a higher tax base we build roads and intersections, schools and fire stations. So long as the developer has done a decent job of creating infrastructure to be conveyed to the City (and hasn't conveyed an unreasonable maintenance issue), and had contributed to known burdens on the City (they build and dedicate infrastructure, etc.) - I support reasonable development.
Brodie
--
Brodie Stephens
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From: Marjorie Morgenstern
To: Mike Maloney
Subject: Fw: Questions For Tomorrows Meeting
Date: Tuesday, December 9, 2025 5:33:51 PM
Attachments: MasoniteSiteClosureReport.pdf
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From: Jennifer Sullivan <[email protected]> Sent: Tuesday, December 9, 2025 12:02 PM
To: Todd Lands <[email protected]>; Brian Wheeler <[email protected]>; Mark Laskey <[email protected]>; Andres Marquez <[email protected]>; Marjorie Morgenstern
<[email protected]>
Subject: Questions For Tomorrows Meeting
Dear City Council,
I hope I am going about this email the right way....but I'd like to submit to the public record or for the public to have access to if they don't already have access to it on the City of Cloverdale website as it relates to the proposed Esmeralda development and our most treasured public resource, water.
See Attached: The Site Closure Former Masonite Wood Treatment Facility Cloverdale, California Prepared for: International Paper Company Memphis, TN by AECOM Environment.
It's quite the read if you haven't already read it.
This email below is from that report.
Dickerson, Robert@Waterboards Tuesday, July 05, 2016 1:34 PM Thomas Neely John Shaw; Jes Slavik; Alan Anselmo; Andrew Zamberlin
RE: Masonite Cloverdale Parcel-Environmental Covenant and Development Plan Good Afternoon Tom,
I reviewed your question with my counsel regarding whether a hotel use or time-share units are included in the definition of “residence for human habitation” and whether such development and use would be permitted on the Burdened Property. The answer is no because this use is not specifically discussed in the covenant and these are residences, although temporary; however, the covenant can be rewritten to include this use. In order to support this change, the responsible party will need to demonstrate that use of the property for hotel use or time-share units in the restricted area will not impact human health and safety, or the environment. This could be accomplished by a site specific risk assessment that accounts for the proposed use, local conditions and other pertinent information. Please contact me with any 403
questions. Thanks. Rob
----
It sounds to me like the City Council or planning is working to rezone the Masonite site to mixed/residential? Is there precedent of rezoning a similarly PCP "burdened" property successfully to mixed/residential next to a watershed? Has or is Esmeralda Land Company conducting a "site specific risk assessment that accounts for the proposed use, local conditions and other pertinent information." Deed restrictions have mitigated risks to the Russian River watershed and to public health. There will be an impact for disturbing land that while remediated, is still polluted with one of the most toxic substances on earth.
Does Esmeralda Land Company have a liability waiver should something go wrong? Is this why investors remain private?
There's another way for Smart Train and Cloverdale. I know how sweet the promised jobs and increased tax revenue sounds, but at what cost? I know how hard the position you are in is, and empathize but redeveloping/rezoning this site for residential use comes with massive public health and resource risk.
Thank you kindly,
Jennifer Sullivan
--
Jennifer Sullivan
Writer & Parkinson's Content Creator
YouTube | Instagram | Substack
www.thewigglesproject.com
www.jenniferlouisesullivan.com
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From: Erik Terreri
To: Public Comments; City Council
Cc: Nenna
Subject: City Council - Support for Esmeralda
Date: Tuesday, December 9, 2025 11:09:02 PM
Honorable City Council Members and Public Comments,
You know me and how much effort I devote to making Cloverdale a better place with respect for its small town community character.
I serve as the Chair of the Cloverdale Leadership Council, which facilitates collaboration and community engagement amongst our community organizations, non profits, and the City.
I serve on the board of directors of both the Arts Alliance and the Chamber of Commerce, I am also a Rotarian and organize the monthly Rotary Bingo.
Most of you know me for my work in Real Estate. My background is in economics. I have a degree in Environmental Economics from UCB and a masters from Caltech. I’m currently chairing the economic development committee through the Chamber of Commerce.
The project proposed by Esmeralda fits within the City of Cloverdale and the arguments against it simply don’t hold water. There is no ability for this development to create an independent state. And, fair housing laws simply don’t allow for discrimination based on who someone is.
I have no economic stake in the development. I strongly believe that this development will help Cloverdale small businesses by increasing demand. The tax revenue and impact fees will also help the City budget. The benefits to Cloverdale far outweigh any of the negatives that people are alleging.
What Devon and her team have proposed fits with the prior CEQA work and in fact is smaller in scope, and environmentally is much better than prior proposals.
Prior development attempts have failed because of the risk. There’s no guarantee that the project - phased in over 10/11 years - will succeed. But, we have a developer willing to take that risk and invest in public access River front open space for our community and their development. They will be building a hotel with amenities that will bring tourists and visitors to our town and TOT and sales tax revenue.
Specific to water, their proposal includes ground water recharge by a system for capturing excess water from the river during high water events, storing it and allowing ground water recharge.
The scope of this project is smaller than previously approved development and provides more benefits to Cloverdale and its residents.
Will it solve all our problems? No.
Will it create problems? Unlikely.
Will it enhance our quality of lives? Yes.
There is no valid reason at this point to deny approval of this project. Other than fear and conspiracy theories.
I strongly urge you to take emotion and fear out of the equation and allow the project to move forward without delay. Give them a chance to succeed where others have walked away. Welcome our new neighbors to our town in a spirit of collaboration and partnership.
With respect and a deep love of our Town,
Erik Terreri
415.519.0706
[email protected]
Sent from my iPhone
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From: Bruce Goetz
To: City Council; Mark Laskey; Andres Marquez; Kevin Thompson; Planning Commission; Melissa Spingler; Chad Asay; Cory Cadle; Craig Carni; William Wagy; Daniel Frankston; Jason Williams; Alex Mog at Redwood Subject: No Esmeralda Project
Date: Wednesday, December 10, 2025 9:10:43 AM
No Esmeralda!!!
We are writing to let you know that we object to the Esmeralda project.
We have lived in Sonoma county our entire lives, we have watched our towns grow. We know growth happens but control needs happen also. Look at what has happened to small Santa Rosa, the growth of Sonoma and Healdsburg with all that rich and specialty groups. They take over our beautiful land and our quiet communities. Some of us want to hold on to the quiet communities with our simpler lives and inconveniences, that is why we live here. Please don’t let the rich take over our towns peace and quiet and bring their special non inclusive ways here.
Bruce, Monica and Benjamin Goetz
117 Grape Gables Way
Sent from my iPhone
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From: craig tallman
To: Public Comments
Subject: Public Comment – Request for Conditions on the Esmeralda WSA/WSV Date: Wednesday, December 10, 2025 12:29:27 PM
Mayor, Councilmembers, and Staff,
I am writing to comment on tonight’s agenda item regarding adoption of the Water Supply Assessment and Water Supply Verification (WSA/WSV) for the Esmeralda project. I support thoughtful development, but uncertainties in our future water supplies require caution with these types of decisions.
First, the WSA does not analyze peak summer demand, which is when the City’s wells and the Russian River are most stressed. Annual averages cannot substitute for peak-season analysis, especially for a resort-intensive mixed-use project.
Second, the assessment acknowledges but does not quantify hydrologic changes expected from the Potter Valley Project decommissioning, which will reduce late-summer flows.
Without modeling those conditions, the long-term conclusions remain incomplete.
Third, Cloverdale’s pre-1914 water right was curtailed in 2021, yet the WSA does not model a repeat or multi-year curtailment scenario. This is a significant omission in evaluating risk.
Given these uncertainties, I urge the Council to adopt the WSA only with a reopener clause.
This clause would allow the City to require additional water-mitigation measures if future droughts, regulatory actions, or hydrologic changes invalidate key WSA assumptions. It is a prudent safeguard that protects the City without stopping the project.
Additional reasonable conditions include requiring non-potable irrigation systems and tying later phases to updated water-supply information in the 2025 Urban Water Management Plan.
Thank you for considering these protections for Cloverdale’s long-term water reliability.
Respectfully,
Craig Tallman
Cloverdale, CA
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From: Pam Browning
To: Public Comments
Subject: Questions Re: Esmeralda
Date: Wednesday, December 10, 2025 12:53:10 PM
I would like to submit three questions to all the Councilmembers and for the record.
1.) Who are the original and largest investors in Esmeralda?
2.) Wouldn’t it be wise for the Council and the community to know who the major investors are, to assess financial health, risks, legal compliance, and overall fit, preventing fraud and ensuring alignment before significant capital is committed. This vetting confirms the reliability and potential success of the partnership for both parties, acting as a critical risk management step.
3.) Devon mentioned at the last Council meeting that if Esmeralda's hotel fails to gain full occupancy, then the project would not be able to proceed as planned. What would happen then?
Thank you.
Pam Browning
1346 Wilson Rd.
Cloverdale
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From: Marjorie Morgenstern
To: Mike Maloney
Subject: Fw: Letter of support: Esmeralda’s proposal for the AVR site Date: Wednesday, December 10, 2025 1:35:57 PM
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From: Martine Matejczyk <[email protected]>
Sent: Wednesday, December 10, 2025 1:23:43 PM
To: Todd Lands <[email protected]>; Brian Wheeler <[email protected]>; Andres Marquez <[email protected]>; Marjorie Morgenstern <[email protected]>; Mark Laskey <[email protected]>; Kevin Thompson <[email protected]>
Cc: Alex Mog at Redwood <[email protected]> Subject: Letter of support: Esmeralda’s proposal for the AVR site Dear City Council Members and City Manager:
I'm submitting this letter in support of Esmeralda for the December 10th meeting.
I've lived in Sonoma County for 5 years, and I want to focus on one specific element that matters deeply to me: the public park.
I appreciate the efforts that the Esmeralda team have gone to to hear feedback from the local community and integrate it into their plan. I truly wish them the best with their efforts. From water use, to local community, to integration with the landscape, I think their project will become a special spot for many people and generations to enjoy. I wish I could have grown up in a community like Esmeralda, hopefully someday I can participate in one.
Too often, new developments feel like islands: separate from the rest of the community, with amenities that only residents can access. Esmeralda is taking a different approach.
The park they're proposing isn't a gated amenity. It's a genuine public space, open to everyone in Cloverdale. That means a family living across town can bring their kids there. That means someone who doesn't live in the development can meet friends there for a picnic. That means it becomes part of our broader community fabric, not just a perk for residents.
This is how you integrate new development with existing neighborhoods—you create shared spaces where people from different parts of town naturally interact and build connections.
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I hope you'll approve the Water Supply Assessment and allow this project to continue.
Thank you,
Martine Matejczyk
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From: Joe Wiedman
To: Public Comments
Subject: Esmeralda project
Date: Wednesday, November 19, 2025 7:44:55 PM
Dear City Council & staff,
I support the Esmeralda project as it will take an unused parcel of land to create more housing, business growth, and employment opportunities. It will also result in a massive increase in long term property tax revenue our city desperately needs.
I encourage city leaders to carefully scrutinize all the expenses the city will incur as a result of the project (such as water recycling) to ensure the developers pay the cost of these upgrades prior to the city incurring the expenses.
Thank you for your leadership & time.
Regards,
Joe Wiedman
Cloverdale, CA
Sent from my iPhone
411
From: [email protected]
To: Public Comments; City Council; Todd Lands; Brian Wheeler; Marjorie Morgenstern; Mark Laskey; Andres Marquez; Kevin Thompson; Kevin Thompson; Planning Commission; Melissa Spingler; Chad Asay; Cory Cadle; Craig Carni; William Wagy; Daniel Frankston; Jason Williams; Alex Mog at Redwood; Cegielski, Sabrina S.@Waterboards
Cc: Michael Knudtzon; Palomino Water; Pete Sourek; Rob Davis Subject: A letter to Cloverdale City Council, Planning Commission, City manager & City Attorney Date: Tuesday, December 9, 2025 12:27:19 PM
RE: Lake Pillsbury decommissioning and water issues
It is known that the proposed elimination of Lake Pillsbury and decommissioning of the PG&E power station puts all water users of Russian River water from Potter Valley to Healdsburg at risk by significantly reducing summer flows in the river, especially during periods of drought.
The Palomino Lakes Community and the Palomino Lakes Mutual Water Company can not comment directly to the Cloverdale City Council & Planning Commission on the Esmeralda Project, as we are not Citizens of Cloverdale, but must make it abundantly clear that Cloverdale’s increased demand on potable water (by current and proposed expansion of residential housing) and the resulting increased flow of waste water into the Russian River from Cloverdale’s Municipal Waste Treatment Plant (CMWTP) would put all users of Russian River water below Cloverdale to Healdsburg at risk and negatively impact the quality of healthful water diverted by wells from the Russian River for agriculture, and individual and community potable water systems.
By adding tertiary treatment equipment to the CMWTP, a calculated percentage of the total gallons of output could be used for agricultural and landscape irrigation to offset the demand of potable water for these same uses. Lower flows in the summer and in drought periods exacerbate the negative impact of the CWWTP effluent entering the river. An engineered tertiary treatment system would need to be expanded as development loads are increased.
I urge the Cloverdale City Council, the Planning Commission and the citizens of Cloverdale be forward thinking and find funding (either by Government Grants or adding a conditional use fee component to future residential developments for supporting $’s).
I wish to address the Council and Planning body in the public comments section at the beginning of December 10th., 2025 meeting
Thank you,
Lee Edmond Tolbert
Palomino Lakes Mutual Water Company
System Manager
412
From: Molly Fisher
To: Public Comments
Subject: Water
Date: Friday, December 5, 2025 9:18:50 AM
Honorable Mayor and City Council Members,
I’ve been reading the recent water supply assessments as well as reviewing the details of the state grants we’ve been awarded. The conclusion I’ve come to is actually very hopeful:
Cloverdale has a unique opportunity to secure our own water future, right now, without waiting for the dust to settle on the decommissioning of Scott Dam.
We have the money, and we have the plan. I am asking the Council to move three specific projects, which are already included in the City of Cloverdale Five-Year Capital Improvement Program, to the very top of the priority list immediately.
First, we need to expedite the well rehab that the City already has underway.
We have secured a $3 million grant from the Department of Water Resources. The second phase contract has been awarded. We need to complete the rehabilitation of Wells #7 and #8 that has been on deck since 2023.
Right now, when the river gets low, those wells suck in air and debris. According to the final EKI Water Supply Assessment and Water Supply Verification report of November 2025, by fixing these wells, the City will save an estimated 13 million gallons of water per year.
That is 13 million gallons we don’t have to pump from the river. That is effectively a “virtual reservoir” that we can access just by completing the work we’ve started.
Second, we need to confirm and map what is happening underground.
Part of that same well project involves drilling exploratory borings 200 feet down. This is more than just construction; this is our chance to verify the science.
The geologic reports suggest there may be a deeper aquifer on the west side of the river. If we analyze those soil samples and confirm the presence of a deeper layer, we open the door to actual Aquifer Storage and Recovery. That means in January, when the river is high, we can take that water and bank it underground for August. We need to make sure we aren’t just drilling holes, but analyzing that data to prove we can bank water.
Finally, we need to implement the modernizations that will give water managers realtime feedback.
We need to fast-track the Advanced Metering Infrastructure and the SCADA system upgrades.
If we are going to run a self-reliant system, our water managers need a real-time, precisionmetered dashboard of what is coming in and what is going out—and keep it secure.
We talk a lot about resilience. These three projects—the well rehab, the deep aquifer testing, 413
and the metering—are what resilience actually looks like. They are funded, they are partly done already, and they put Cloverdale in control of its own destiny.
I urge you to expedite these projects. I believe you can allay some of the community’s fears about growing our City by showing us that your work is already solving the problem we’re worried about. You have done a lot of good work since the curtailment days of 2021.
Thank you!
Molly Fisher
102 Syrah Ct.
Cloverdale, CA 95425
(707) 477-6456 cell
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From: Brian Wheeler
To: Mike Maloney
Subject: Fw: Esmeralda Project and Water
Date: Wednesday, December 10, 2025 3:17:38 PM
Another one to print.
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From: Lynn Caruso <[email protected]>
Sent: Wednesday, December 10, 2025 2:57:51 PM
To: Brian Wheeler <[email protected]>
Subject: Esmeralda Project and Water
Dear Vice Mayor Wheeler,
My husband and I have deep concerns about the Esmeralda Project and its long-term effect on Cloverdale’s water supply.
I know you are already active on our behalf, advocating for Cloverdale’s interests in the Russian River diversions that will occur under the current plan.
We further believe that the state-mandated housing increases will further strain the city’s water supply in drought years.
Thank you for continuing to advocate for Cloverdale’s long-term water needs.
Sincerely, Lynn and Ron Caruso
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City Council/Successor Agency
Agenda Item Summary Meeting Date: December 10, 2025
Agenda Section:
New Business
Staff Contact:
Kevin Thompson, City Manager
Mike Maloney, City Clerk
Agenda Item Title:
Review and discussion of Updated City Council 2026 Subcommittee, Joint Committee and Regional Board/Committee Appointments
_______________________________________________________________________________________ Recommended Council Action(s):
1. Provide direction on the continuation, modification, or consolidation of existing subcommittees.
2. Discuss and determine appointments for City Council subcommittees, joint committees, regional boards, and liaison positions listed below.
________________________________________________________________________________________ Background:
Cloverdale Municipal Code Chapter 2.06 outlines the structure and purpose of City Council subcommittees.
Section 2.06.040 specifies that:
• Each subcommittee consists of two City Councilmembers—one serving as Chair—and the City Manager.
• Council members serve a one-year term or until a successor is appointed. • Subcommittee appointments are made by majority action of the Council, typically at the first regularly scheduled meeting in January.
In addition to City subcommittees, several regional boards require formal Council appointment of representatives. In some cases, bylaws mandate that both primary and alternate representatives must be elected officials. These include:
• Sonoma Clean Power
• Sonoma County Transportation Authority
• Northern Sonoma County Air Pollution Control District These boards do not have any opening this year and will be consider for appointment next year. ________________________________________________________________________________________ Summary:
Beginning in 2025, and based on prior Council direction, staff consolidated the Planning & Sustainability Subcommittee with the Police, Finance, and Administration Subcommittee into what is now the Administration Subcommittee. Additional discussion has since occurred regarding the long-term role and necessity of subcommittees.
The Council may wish to consider the following options:
1. Maintain all existing subcommittees as scheduled, including Finance, Infrastructure, and City & School.
2. Maintain all existing subcommittees but meet only as needed.
3. Eliminate subcommittees entirely, bringing all related items directly to the full City Council. 425
The collected preferences—along with any recommended subcommittee adjustments, meeting frequencies, and appointment options—will be presented at the January 13, 2026, City Council meeting for Council review and final action.
Subcommittees and liaison roles to be discussed include:
• Administration Subcommittee
• Infrastructure Subcommittee
• City/School Subcommittee
• Cloverdale Chamber of Commerce Liaison
• Cloverdale Senior Center Liaison
• Planning Commission Liaison
• Cloverdale Rancheria Tribal Council Liaison
• Cloverdale Regional Library Advisory Board
• League of California Cities – Board of Directors
• League of California Cities – Redwood Empire Division Legislative Committee • Redwood Empire Municipal Insurance Fund (REMIF/CIRA)
• Russian River Watershed Association (RRWA)
_______________________________________________________________________________________ Alternative Options:
Provide alternative direction to staff.
________________________________________________________________________________________ Budget/Financial Impact:
None
________________________________________________________________________________________ 426
City Council/Successor Agency
Agenda Item Summary Meeting Date: December 10, 2025
Agenda Section:
New Business
Staff Contact:
Mike Maloney, City Clerk
Agenda Item Title:
Annual Adoption of the City Proclamation Calendar
_______________________________________________________________________________________ Recommended Council Action(s):
Approve by motion the 2026 Proclamation Calendar
________________________________________________________________________________________ Summary:
The proposed action formally adopts the 2026 proclamation calendar, which is prepared each year so staff can plan regular recognitions and keep meeting schedules consistent. The list reflects the standard proclamations traditionally issued by the City Council and does not limit the ability to consider additional requests submitted through the City’s established request process. ________________________________________________________________________________________ Background:
Proclamations are ceremonial recognitions issued by the City Council to honor causes of community significance. To ensure meetings remain focused and efficient, no more than two proclamations are typically scheduled per meeting. Each year, the City Council will designate an annual calendar of standard proclamations to be issued throughout the year. The Mayor selects the recipient. Any additional proclamation requests must be submitted using the City’s Proclamation Request Form. Requests will be reviewed by the Mayor and City Manager for consideration and potential placement on a future agenda. ________________________________________________________________________________________ Calendar:
January 14th - None
January 28th - None
February 11th - Black History Month
February 25th - None
March 11th - American Red Cross Month
March 25th - Women’s History Month &
Gov. Finance Professionals Week
April 8th - Dispatchers Week (NPSTW) &
Week of the Young Child
April 22nd - Administrative Professionals Week &
Autism Awareness Month
May 13th - National Municipal Clerks Week & Older
Americans Month, Jewish Heritage Month
May 27th - National Police Week &
Public Works Week & Lyme Disease Awareness
June 10th - Pride Month
June 24th - Elder Abuse Month & National Cancer
Survivors Month
July 8th - Traditionally Canceled
July 22nd - Parks and Recreation Month &
Disability Pride Month
August 12th - National Night Out
August 26th - Women’s Equality Day
September 9th - None
September 23rd - Creek Week / National Public
Lands Day & Latino Heritage Month
October 14th - Water Professionals Week
October 28th - None
November 11th - National Veterans and Military
Families Month, Native American Heritage Month
November 25th - Traditionally Canceled
December 9th - None
December 23rd - Traditionally Canceled
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City Council/Successor Agency Agenda Item Summary
Meeting Date: December 10, 2025